Rectification cannot reopen merits where the Tribunal has already addressed precedent and denied exemption benefit on the facts.

Rectification under the Tribunal's limited review power was unavailable because no mistake apparent on the face of the record was shown. The Tribunal had already considered the cited earlier decisions and explained why they did not apply on the facts. It also held that the inputs were not fully duty paid, so benefit of Notification No. 208/83-C.E. was not available. A rectification application cannot be used to reargue the merits or seek a different inference from conclusions already recorded. The request for rectification was therefore rejected and the assessee's challenge failed.

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Issues: Whether the final order of the Tribunal suffered from any mistake of fact or law apparent on the face of the record so as to warrant rectification, particularly on the availability of the benefit of Notification No. 208/83-C.E. to the assessee.

Analysis: The applications sought to reopen findings already recorded in the final order on the ground that two earlier decisions had not been applied. The record showed that the Tribunal had already considered those decisions and had given reasons for holding them inapplicable on the facts. The order also found that the inputs were not fully duty paid and that the benefit of the exemption notification was therefore unavailable. A rectification application cannot be used to reargue the merits or to challenge a concluded view merely because a different inference is pressed later.

Conclusion: No mistake apparent on the face of the record was established. The request for rectification was rightly rejected and the outcome remained against the assessee.

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