CIT v. Hero Cycles (P.) Ltd.

228 ITR 463Supreme Court of India1997#318 most cited

What is CIT v. Hero Cycles (P.) Ltd. authority for?

A point not examined on facts or in law cannot be treated as a mistake apparent on record for rectification purposes.

262

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2011 to 2026.

Also referred to as

CIT v. Hero Cycles (P.) Ltd. · Hero Cycles · 228 ITR 463 · 94 Taxmann 271 · mistake apparent on record · rectification · point not examined · facts or law · Section 143(3) · Section 14A

Also reported as

94 Taxmann 271

Sections most often in play

Section 143(3)Section 153ASection 115JBSection 14ASection 153DSection 153B(1)(b)Section 250Section 148

Issues it is cited on

section 234e(1)installation pesection 119(1)use of equipmentsection 253(2)dependent agent pesection 119(2)(a)section 44dagency peservice pefunctional analysissection 200a(1)(c)

Judgments citing CIT v. Hero Cycles (P.) Ltd.

Deputy Commissioner of Income Tax, Central Circle 6(2), Mumbai vs. Tata Aig General Insurance Co. Ltd, Mumbai

In the result the appeal of the revenue’s bearing ITA No

ITA 2398/MUM/2024[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)
Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

…s. CIT [1999] 237 ITR 889 (SSC). “13.1 It is also important to note about the binding nature of CBDT circular on the Income-tax Authorities for which gainful guidance is taken from the decision of Hon'ble Supreme Court in the case of CIT u. Hero Cycles [1997] 228 ITR 463 (SC) wherein it was held that circulars bind the ITO but will not bind the appellate authority or the Tribunal or the Court or even the assessee. 13.2 In the case of UCO Bank [1999) 237 ITR 889 (SC), Hon'ble Supreme Court while dealing with the legal status of such circulars, observed thus (page 896): "Such instructions may be by way of relaxati…

Tata Aig General Insurance Company Limited, Mumbai vs. Assistant Commissioner of Income-Tax-8(3)(1), Mumbai

In the result the appeal of the revenue’s bearing ITA No

ITA 1450/MUM/2024[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Jagadish

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Ritesh Misra (CIT DR)
Section 10(38)Section 111ASection 112Section 139(1)Section 143(3)Section 234ASection 234BSection 234DSection 250

…s. CIT [1999] 237 ITR 889 (SSC). “13.1 It is also important to note about the binding nature of CBDT circular on the Income-tax Authorities for which gainful guidance is taken from the decision of Hon'ble Supreme Court in the case of CIT u. Hero Cycles [1997] 228 ITR 463 (SC) wherein it was held that circulars bind the ITO but will not bind the appellate authority or the Tribunal or the Court or even the assessee. 13.2 In the case of UCO Bank [1999) 237 ITR 889 (SC), Hon'ble Supreme Court while dealing with the legal status of such circulars, observed thus (page 896): "Such instructions may be by way of relaxati…

DCIT, Cir-5(1), Kolkata vs. M/S Coal India Ltd., Kolkata

ITA 1697/KOL/2019[2014-15]Status: DisposedITAT Kolkata20 Jan 2026AY 2014-15

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

…e assessee nor appellate authorities in view of the decisions in the following cases: (a) Customs Calcutta vs Indian Oil Corporation Ltd [(2004) 165 ELT 257 (SC)] (b) Vikrant Tyres vs First ITO [(1993) 202 ITR 454 (Kar)] (c) CIT vs Hero Cycles (P) Ltd [(1997) 228 ITR 463 (SC)] 4.3 With regard to the addition under book profits, it is submitted by the Ld. AR that section 115JB is a self-contained code. Explanation to section 115JB of the Act provides certain adjustment to be made in the computation of book-profit. Apart from the adjustments mentioned in the said Explanation, no other adjustment can be made in the…

DCIT, Circle - 5(1), Kolkata vs. M/S. Coal India Limited, Kolkata

ITA 623/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13
Section 115JSection 250

…e assessee nor appellate authorities in view of the decisions in the following cases: (a) Customs Calcutta vs Indian Oil Corporation Ltd [(2004) 165 ELT 257 (SC)] (b) Vikrant Tyres vs First ITO [(1993) 202 ITR 454 (Kar)] (c) CIT vs Hero Cycles (P) Ltd [(1997) 228 ITR 463 (SC)] 4.3 With regard to the addition under book profits, it is submitted by the Ld. AR that section 115JB is a self-contained code. Explanation to section 115JB of the Act provides certain adjustment to be made in the computation of book-profit. Apart from the adjustments mentioned in the said Explanation, no other adjustment can be made in the…

DCIT, Circle - 5(1), Kolkata vs. M/S. Coal India Limited, Kolkata

ITA 622/KOL/2018[2011-12]Status: DisposedITAT Kolkata20 Jan 2026AY 2011-12

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

…e assessee nor appellate authorities in view of the decisions in the following cases: (a) Customs Calcutta vs Indian Oil Corporation Ltd [(2004) 165 ELT 257 (SC)] (b) Vikrant Tyres vs First ITO [(1993) 202 ITR 454 (Kar)] (c) CIT vs Hero Cycles (P) Ltd [(1997) 228 ITR 463 (SC)] 4.3 With regard to the addition under book profits, it is submitted by the Ld. AR that section 115JB is a self-contained code. Explanation to section 115JB of the Act provides certain adjustment to be made in the computation of book-profit. Apart from the adjustments mentioned in the said Explanation, no other adjustment can be made in the…

Coal India Limited, Kolkata vs. DCIT, Circle - 5(1), Kolkata

ITA 467/KOL/2018[2012-13]Status: DisposedITAT Kolkata20 Jan 2026AY 2012-13

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115JSection 250

…e assessee nor appellate authorities in view of the decisions in the following cases: (a) Customs Calcutta vs Indian Oil Corporation Ltd [(2004) 165 ELT 257 (SC)] (b) Vikrant Tyres vs First ITO [(1993) 202 ITR 454 (Kar)] (c) CIT vs Hero Cycles (P) Ltd [(1997) 228 ITR 463 (SC)] 4.3 With regard to the addition under book profits, it is submitted by the Ld. AR that section 115JB is a self-contained code. Explanation to section 115JB of the Act provides certain adjustment to be made in the computation of book-profit. Apart from the adjustments mentioned in the said Explanation, no other adjustment can be made in the…

Piyush Garg, Ahmedabad vs. DCIT, CC-1(2), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 1590/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2022-23

For Appellant: Shri Anurag Sinha, A.RFor Respondent: Shri Uday Kishanrao Kakne, Sr. D.R
Section 115BSection 132ASection 143(1)Section 143(3)Section 154Section 271A

…. Further, it is an admitted position (as noted by the Ld. CIT(A) himself) that the applicability of section 271AAC(1) is a debatable issue. The Hon'ble Supreme Court in T.S. Balaram, ITO v. Volkart Bros. (1971) 82 ITR 50 (SC) and CIT v. Hero Cycles (P) Ltd. (228 ITR 463, SC) has categorically laid down that issues which are debatable cannot be rectified under section 154. Thus, the very assumption of jurisdiction by the AO under section 154 was bad in law. If the issue is debatable and requires discussion of law or facts, it falls outside the scope of section 154. In the present case, the AO has passed the recti…

Smithkline Beecham Consumer Brands Ltd vs. Commissioner of Income Tax Patiala

ITR/62/1995HC Punjab & Haryana27 Nov 2025
Section 143Section 35BSection 40Section 40A(5)

…IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH **** 201 Date of Decision: 27.11.2025 1. ITR-62-1995 M/S.SMITHKLINE BEECHAM CONSUMER HEALTHCARE LTD. ...Petitioner Versus COMMISSIONER OF INCOME TAX ...Respondent 2. ITR-63-1995 M/S.SMITHKLINE BEECHAM CONSUMER HEALTHCARE LTD. ...Petitioner Versus COMMISSIONER OF INCOME TAX ...Respondent 3. ITR-64-1995 M/S.SMITHKLINE BEECHAM CONSUMER HEALTH CARE LTD. ...Petitioner Versus…

Prakashbhai Manchharam Mistry, Surat vs. Income Tax Officer, Ward 3(2)(1), Surat

In the result, appeal of the assessee is dismissed

ITA 132/SRT/2025[2012-13]Status: DisposedITAT Surat04 Nov 2025AY 2012-13

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.132/Srt/2025 Assessment Year: (2012-13) (Hybrid Hearing) Prakash Manchharam Mistry, Vs. The Ito, 57, Viramnagar Society, Dabholi, Ward – 3(2)(1), Surat - 395004 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aqtpm1279Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Ketan Jagirdar, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 07/08/2025 Date Of Pronouncement 04/11/2025

Section 142(1)Section 144Section 148Section 154Section 250Section 50C

…on the record must be an obvious and patent mistake and not something, which can be established by a long-drawn process of reasoning on points on which there may conceivably be two opinions. The Hon’ble Supreme Court in case of CIT vs. Hero Cycles Pvt. Ltd., 228 ITR 463 (SC) held that a point which was not examined on fact or in law cannot be dealt as mistake apparent on the record. Similarly, in case of CIT vs. Keshri Metals Pvt. Ltd., 237 ITR 165 (SC), it was held that reference to documents outside the records and the law is impermissible when applying the provisions of section 154 of the Act. We find that th…

Baani Landbase Private Limited, New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, appeal of the Assessee is allowed

ITA 5944/DEL/2024[2015-16]Status: DisposedITAT Delhi30 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A No.5944/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Baani Landbase Pvt Ltd., Dcit, Corporate One, Ground Floor, Vs. Circle-4(2), Plot No.5, District Center, Jasola, Central Revenue Building, Delhi. I.P. Estate, Delhi. Pan No.Aadcb0237E अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 148Section 154Section 156Section 292B

…which can be established by a long drawn process of reasoning on points on which there may be conceivably two opinions. Ld. Counsel for the assessee further placing reliance on the decision of the Apex Court in the case of CIT vs. Hero Cycles 4 Pvt. Ltd. (228 ITR 463) submitted that the Hon’ble Apex Court held that “a point which was not examined on facts or in law cannot be dealt with as a mistake apparent on record”. Reliance was also placed on the decision of the jurisdictional High Court in the case of CIT vs. Hindustan Cycles & Tubes Ltd. (147 Taxman 555) and the Hon’ble Madras High Court in the case of…

Mcm Developers, Aurangabad vs. DCIT. Central Circle-1, Aurangabad

In the result, the appeal filed by the assessee is allowed

ITA 362/PUN/2025[2018-2019]Status: DisposedITAT Pune17 Sept 2025AY 2018-2019

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Pramod ShingteFor Respondent: Shri Amol Khairnar
Section 143(3)Section 153ASection 153CSection 154Section 269SSection 270ASection 271DSection 40A(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA No.362/PUN/2025 िनधा"रण वष" / Assessment Year : 2018-19 MCM Developers, Vs. DCIT, Central Circle-1, 2nd Floor, Tapadiya Aurangabad. Terraces, Adalat Road, Aurangabad- 431001. PAN : AAXFM0436D Appellant Respondent Assessee by : Shri Pramod Shingte Revenue by : Shri Amol Khairnar Date of hearing : 07.08.2025 Date of pronouncement : 17.09.2025 आदेश / ORDER PER VINAY BHAMORE, JM: This appeal filed by the assessee is directed against the order dated 16.12.20…

Elca Cosmetics Pvt Ltd, Delhi vs. DCIT, Circle-7(1), Delhi

In the result, the appeal of the assessee in ITA No

ITA 1571/DEL/2025[2015-16]Status: DisposedITAT Delhi19 Aug 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Nishant Thakkar, AdvFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(3)Section 154

…e assessee placed reliance on the decision of the co-ordinate bench in Bayer Bioscope in ITA No. 5388/M/2009 Page 4 of 9 [A.Y. 2015-16] ELCA Cosmetics Pvt Ltd order dated 21.04.2016 and the decision of the Hon'ble Supreme Court in the case of Hero Cycles 94 Taxmann 271 order dated 28.08.1997. 8. On the other hand, the ld. DR relied upon the orders of the authorities below. 9. We have heard the rival submissions and have perused the relevant material on record. We find that the co-ordinate bench in the case of Bayer Bioscope [supra] has extensively dealt with the issue of taxability of provisions of sales…

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Ltd), Mumbai vs. Assistant Commissioner of Income Tax Central Circle 8(1), Mumbai

In the result, the appeals filed by the assessee are

ITA 5423/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Jul 2025AY 2020-21
Section 115JSection 132Section 143(3)Section 153ASection 69A

…ed that CBDT circulars are only binding on the department and not binding on the 78 ITA No.2227/Mum/2024 and others Mahadhan Agritech Limited assessee or on the appellate authorities. Reliance in this regard was placed on: - CIT vs.Hero Cycles (P) Ltd. [1997] 228 ITR 463 (SC) - UCO Bank vs. CIT [1999] 237 ITR 889 (SC) 124. Reliance was also place by the ld. AR on the following decisions wherein even after considering the aforesaid Circular, it has been held that no disallowance u/s 14A can be made in the absence of exempt income: - CIT vs. Chettinad Logistics (P) Ltd (supra) - Redington (India) Ltd. vs. ACIT [201…

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Limited ), Mumbai vs. Deputy Commissioner of Income Tax, Central Circle -8(1), Mumbai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 3937/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

…ee has not earned any exempt income. 123. The ld. AR submitted that CBDT circulars are only binding on the department and not binding on the assessee or on the appellate authorities. Reliance in this regard was placed on: - CIT vs.Hero Cycles (P) Ltd. [1997] 228 ITR 463 (SC) UCO Bank vs. CIT [1999] 237 ITR 889 (SC) - 124. Reliance was also place by the ld. AR on the following decisions wherein even after considering the aforesaid Circular, it has been held that no disallowance u/s 14A can be made in the absence of exempt income: CIT vs. Chettinad Logistics (P) Ltd (supra) - Redington (India) Ltd. vs. ACIT [2017…

DCIT Central Circle 8(1), Mumbai vs. Mahadhan Agritech Limited, Pune

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 3569/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

…ee has not earned any exempt income. 123. The ld. AR submitted that CBDT circulars are only binding on the department and not binding on the assessee or on the appellate authorities. Reliance in this regard was placed on: - CIT vs.Hero Cycles (P) Ltd. [1997] 228 ITR 463 (SC) UCO Bank vs. CIT [1999] 237 ITR 889 (SC) - 124. Reliance was also place by the ld. AR on the following decisions wherein even after considering the aforesaid Circular, it has been held that no disallowance u/s 14A can be made in the absence of exempt income: CIT vs. Chettinad Logistics (P) Ltd (supra) - Redington (India) Ltd. vs. ACIT [2017…

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Ltd, Mumbai vs. Commissioner of Income Tax(Appeal)--50, Mumai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 2229/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Jul 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

…ee has not earned any exempt income. 123. The ld. AR submitted that CBDT circulars are only binding on the department and not binding on the assessee or on the appellate authorities. Reliance in this regard was placed on: - CIT vs.Hero Cycles (P) Ltd. [1997] 228 ITR 463 (SC) UCO Bank vs. CIT [1999] 237 ITR 889 (SC) - 124. Reliance was also place by the ld. AR on the following decisions wherein even after considering the aforesaid Circular, it has been held that no disallowance u/s 14A can be made in the absence of exempt income: CIT vs. Chettinad Logistics (P) Ltd (supra) - Redington (India) Ltd. vs. ACIT [2017…

Mahadhan Agritech Limited (Formerly Knwon As Smartech Technologies Ltd ), Mumbai vs. Commissioner of Income Tax (Appeals)-Mumbai-50, Mumbai

In the result, the appeals filed by the assessee are

ITA 2228/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17
Section 115JSection 132Section 143(3)Section 153ASection 69A

…d that CBDT circulars are only binding on the department and not binding on the ITA No.2227/Mum/2024 and others Mahadhan Agritech Limited 79 assessee or on the appellate authorities. Reliance in this regard was placed on: - CIT vs.Hero Cycles (P) Ltd. [1997] 228 ITR 463 (SC) - UCO Bank vs. CIT [1999] 237 ITR 889 (SC) 124. Reliance was also place by the ld. AR on the following decisions wherein even after considering the aforesaid Circular, it has been held that no disallowance u/s 14A can be made in the absence of exempt income: - CIT vs. Chettinad Logistics (P) Ltd (supra) - Redington (India) Ltd. vs. ACIT [201…

Mahadhan Agritech Limited (Formerly Known As Smartech Technologies Ltd, Mumbai vs. Commissioner of Income Tax (Appeals)-Mumbai.50, Mumbai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 2227/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Jul 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

…ee has not earned any exempt income. 123. The ld. AR submitted that CBDT circulars are only binding on the department and not binding on the assessee or on the appellate authorities. Reliance in this regard was placed on: - CIT vs.Hero Cycles (P) Ltd. [1997] 228 ITR 463 (SC) UCO Bank vs. CIT [1999] 237 ITR 889 (SC) - 124. Reliance was also place by the ld. AR on the following decisions wherein even after considering the aforesaid Circular, it has been held that no disallowance u/s 14A can be made in the absence of exempt income: CIT vs. Chettinad Logistics (P) Ltd (supra) - Redington (India) Ltd. vs. ACIT [2017…

Amitkumar Pravinchandra Reshamwala, Surat vs. Deputy Director of Income Tax, CPC Bengaluru / ITO (Int. Tax) Surat, CPC Bengaluru / ITO Surat

In the result, appeal of assessee is dismissed

ITA 1240/SRT/2024[2023-24]Status: DisposedITAT Surat29 May 2025AY 2023-24

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1240/Srt/2024 Assessment Year: (2023-24) (Hybrid Hearing) Amitkumar Pravinchandra Deputy Director Of Income-Tax, बनाम/ Reshamwala Cpc, Bengaluru/Ao (Int. Tax) Vs. B-1004, Arihant Heightsopp Surat Stuti Icon. Auravpath, Palanpur-395 005 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Agspr 4047 K (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 154Section 234BSection 234CSection 250Section 90

…e has been an error, and that error may be rectified. Reference to documents outside the records and the law is impermissible when applying the provisions of section 154 of the Act. 6.5 Again, the Hon’ble Supreme Court in case of CIT vs. Hero Cycle Pvt. Ltd. 228 ITR 463 (SC) held that a point which was not examined on fact or in law cannot be dealt as mistake apparent on record. 6.6 The Hon’ble Supreme Court in case of ACIT vs. Saurashtra Kutch Stock Exchange Ltd., 305 ITR 227 (SC) held that an error cannot be said to be apparent on the face of the record if one has to travel beyond the record to see whether the…

Mc Mowjee & Co Private Limited, Kolkata vs. I.T.O. Ward-4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2118/KOL/2024[2015-16]Status: DisposedITAT Kolkata17 Mar 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito Ward-4(1) Mc Mowjee & Co. Private Aaykar Bhavan, P-7, Limited 118, Tollygunge Circular Road, Chowringhee Square, Vs. Tollygunge, Kolkata-700053, Kolkata-700069 West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabcm7491D Assessee By : Shri Akkal Dudhewala, Ar Revenue By : Shri Arup Chatterjee, Dr Date Of Hearing: 10.03.2025 Date Of Pronouncement : 17.03.2025

For Appellant: Shri Akkal Dudhewala, ARFor Respondent: Shri Arup Chatterjee, DR
Section 143(1)Section 143(3)Section 154Section 40

…this issue involves the interpretation of provision of the Act and therefore, the jurisdiction exercise u/s 154 of the Act is bad in law. The case of the assessee find force from the decision of Hon'ble Apex Court in the case of CIT vs. Hero Cycles (P). Ltd. 228 ITR 463 (SC), wherein Hon'ble Supreme Court held that rectification u/s 154 of the MC Mowjee & Co. Private Limited; A.Y. 2015-16 Act can only be made when glaring mistake of fact or law has been committed by the officer passing the order and it becomes apparent from the record. Rectification is not possible if the question is debatable. Moreover, the poi…