Rectification of advance ruling [Section 102]

Rectification of advance ruling: limited timeframe and corrections allowed only for apparent mistakes with hearing before increasing liability.

Rectification under Section 102 is subject to a six month limit and must not substantially amend the original order; it cannot be used to change interpretative views. Any rectification that increases tax liability or reduces admissible input tax credit requires an opportunity of being heard, with notice to either the applicant or the appellant (service on the appellant suffices if the appellant is the concerned officer). Authorities may correct mistakes apparent on the face of the record, discovered suo motu or brought to notice, but not debatable issues and only where the error is evident from the record without external evidence.