"6.Rectification application under Section 84 of the Act cannot be treated on par with a regular assessment. Only in cases, where there is an error which is apparent on the face of the record in the Assessment Order, a rectification under Section 84 of the Act is permissible. If the opportunity of hearing for the Dealer is made mandatory in an application filed under Section 84 of the Act, there will be no finality of any Assessment. That is the reason as to why the Legislature thought it fit to include the 1 st proviso in Section 84(1) of the Act by making it clear that only in cases, where there is an enhancement of assessment or penalty, the Assessment Officer will have to give an opportunity of hearing to the Dealer and not otherwise. The respondents in the impugned order has examined the request of the petitioner seeking for rectification and only thereafter correctly found that the assessment dated 19.12.2016 for the Assessment Year 2013-14 does not require any rectification. As observed earlier, as per the provisions of Section 84 of the Act, only in cases of enhancement of Assessment or Penalty, the respondents will have to afford an opportunity of hearing
