There was held to be no merit in the contention of the assessee that the refusal to consider Circular No. 6 of 2016 amounts to a mistake apparent from the record which is to be rectified in proceedings under s. 154. As submitted by the counsel for the Revenue, the assessee had raised the very same issue in the rectification application as well as in the appeal filed against assessment order which was pending consideration before the appellate authority. The contention of the assessee in the rectification application touched on the merits of the grounds raised in the regular statutory appeal filed against the assessment order being the applicability of the circular and whether the assessing authority went wrong in disregarding the CDT circular are grounds raised in the appeal by the assessee. This question required adjudication in the appeal by hearing parties on questions of facts and law. Therefore, the issue raised in the application was not held to be a mistake apparent from the record which was to be rectified in proceedings under s. 154. The writ petition was accordingly dismissed. However, it was made clear that the statutory appeal would be considered and decided by the appellate authority in accordance with the law, untrammelled by any observations in orders rejecting the rectification petition.