Satyendra Singh Chauhan, J.;- The revisionist feeling aggrieved with the order dated 3.9.2011 passed by the Tribunal, the order dated 13.10.2009 passed by the appellate authority and the order dated 24.3.2009 passed by the Assessing Authority imposing a tax liability of Rs.20,57,030/- on the revisionist assessee has filed this revision. The facts in brief are that the assessment was done of the revisionist by the Assessing Authority in the year 2004-2005. Certain Forms 3B were filed claiming rebate in respect of tax. The Assessing Authority scrutinized the Forms 3B filed by the revisionist and proceeded to grant rebate to the revisionist. At a later point of time i.e. after one and half years, the Assessing Authority made an inspection and passed an order on 24.3.2009 as he came to the conclusion that certain Forms 3B which were filed were relating to the period two years before which were impermissible to be accepted under Rule 25-B of the U.P. Trade Tax Rules. The Assessing Authority thereafter disallowed the rebate against which an appeal was filed. The appellate authority dismissed the appeal and thereafter a second appeal was filed before the Tribunal, which too has been dismissed vide order dated 3.9.2011. Hence this commercial tax revision. The only point which has been put forward by the learned counsel for the revisionist is that the provisions of Section 22 of the U.P. Trade Tax Act (for short "the Act") have wrongly been interpreted and provisions of Section 22 of the Act were not applicable at all in the case of the revisionist. Apart from it, the order passed by the Assessing Authority amounts to review of the earlier order passed by the earlier Assessing Authority and it also involves an interpretation and therefore, the order passed by the Tribunal as well as by the authorities below is illegal and the rebate which has been granted to the revisionist could not have been interfered with under the garb of Section 22 of the Act. It is also submitted that the power could have been exercised under Section 21 (1) (a) of the Act. It is also submitted that the power could have been exercised under Section 21 (1) (a) of the Act. Learned counsel for the revisionist has placed reliance upon the judgments rendered in the case of Laxminarain Gauri Shanker and Another v. The State of U.P. and another, [1969] 24 STC 77 (All), Kedar Nath Ram Lakhan v. Commissioner of Sales Tax, U.P., [1999] 113 STC 326 (All), Gujarat Co-operative Milk Marketing Federation Limited v. Assistant Commissioner (Assessment) Trade Tax and others (and other cases), [2004] 137 STC 307 (All) and Deva Metal Powders (P) Ltd. v. Commissioner, Trade Tax, Uttar Pradesh, (2008) 2 SCC 439 . Learned Standing Counsel, on the other hand, has submitted that the power under Section 22 of the Act is the only remedy which could have been exercised and it was an error apparent on record and therefore, the Assessing Authority was well within his jurisdiction to rectify the said mistake by exercising power under Section 22 of the Act. It has also been submitted by the learned Standing Counsel that object of Section 22 of the Act has to be taken into consideration while exercising power in such a manner. It is also submitted that power of rectification is something different than the power contemplated under Section 21 (1) (a) of the Act. The order which has been passed has not been passed by entering into any interpretation but in fact the order has been passed on the basis of mistake which was apparent on the record. I have heard learned counsel for the parties and perused the record. Argument of the learned counsel for the revisionist that Section 22 of the Act is not applicable has to be taken into consideration and the very purpose and object of Section 22 of the Act has also to be kept into mind while deciding issues in respect of the mistake which too occur unintentionally during the course of any assessment. The power conferred under Section 22 of the Act is expressed in the manner that if any error is found apparent on the record, then any officer or authority or the Tribunal or the High Court may suo motu correct the said mistake. Forms 3-B were accepted granting rebate. The power conferred under Section 22 of the Act is expressed in the manner that if any error is found apparent on the record, then any officer or authority or the Tribunal or the High Court may suo motu correct the said mistake. Forms 3-B were accepted granting rebate. Thereafter the Assessing Authority made an inspection and came to the conclusion that certain Forms 3-B which were filed were relating to the period two years before than which were permissible to be accepted under Rule 25-B of the U.P. Trade Tax Rules. It has to be presumed that it was an error apparent on the record and the Assessing Authority was well within the power to proceed with the rectification of the mistake. The case laws relied upon by the learned counsel for the revisionist are in different context. Therefore, coming to the point as to whether the power which has been exercised in the present case is covered within the ambit of error apparent on record or it is to be treated as an exercise of interpretation and thereafter imposing any liability upon the revisionist. On the given facts in the present case, I find that it was an error apparent on record which was discernible from the record and as such, the authorities did not commit any mistake in rectifying the said mistake. Reliance placed by the learned counsel for the revisionist in the case of Laxminarain Gauri Shanker (supra) in which it was held that it must be a mistake apparent on the on the face of the record or it must be a mistake which must be patent on the face of the record and does not call for a detailed investigation of the facts or law or require an elaborate argument to establish it. The said proposition of the High Court goes to indicate that there was mistake apparent on the record and it did not require any investigation or elaborate argument. In the case of Kedar Nath Ram Lakhan (supra) again the High Court held that mistake must be apparent on record. It was again held that section does not abrogate the nature and extent of the scrutiny that will make the mistake apparent provided the scrutiny is confined to the record as it is. In the case of Kedar Nath Ram Lakhan (supra) again the High Court held that mistake must be apparent on record. It was again held that section does not abrogate the nature and extent of the scrutiny that will make the mistake apparent provided the scrutiny is confined to the record as it is. It was also held that the mistake either of law or of fact apparent on record can be rectified under the said provisions. The proceedings for rectification to certain extent are proceedings for assessment. The expression "mistake" appearing in Section 22 is not confined to only arithmetic or clerical error alone but it comprehends the errors which after a judicious probe into the record from which it is supposed to emanate are discerned. The court further held that a mistake apparent on record must be obvious and a patent mistake and not something which can be established by a long drawn process of reasoning on points on which there may be conceivably two opinions. In the case in hand that is not the position existing and there is no possibility of two opinions and one can form only one opinion to rectify the aforesaid error, which was apparent from record. In the case of Gujarat Co-operative Milk Marketing Federation Limited (supra) again the same principle was reiterated that the assessing officer was empowered to issue notice under the aforesaid section only when there is an error apparent on the face of record and error apparent on the face of record does not include in its scope that debatable questions of law and fact. An erroneous judgment does not come within the scope of phrase "error apparent on the face of the record". Therefore, the aforesaid case law does not come to the rescue of the revisionist. The Apex Court in the case of Deva Metal Powders (P) Ltd. (supra) also laid down the same principle that a mistake which can be rectified under Section 22 is one which is patent, which is obvious and whose discovery is not dependent on argument or elaboration. Therefore the revisionist's case is altogether on different footing and neither any enquiry is needed nor any elaboration is needed and the error is apparent on the record and as such, the Assessing Authority has committed no illegality in disallowing the rebate. The revision is devoid of merit. It is accordingly dismissed.