Levy of interest under section 220(2) no longer governed by Rule 118 following its omission from the rules. Levy of interest under section 220(2) was regulated by Rule 118 of the Income-tax Rules, but that provision has been removed: Rule 118 was omitted by the Income-tax (Eleventh Amendment) Rules, 1989, and no longer forms part of the Rules governing levy of interest where a recovery certificate is not issued.