Rectification cannot revisit a debatable claim to interest under section 214 when entitlement is not free from doubt.

Rectification under section 154 is limited to mistakes apparent from the record and cannot be used to reopen a debatable issue. Where the assessee's entitlement to interest under section 214 depended on whether late advance tax payments qualified and whether interest was payable under sections 207 to 213, the question was not free from doubt. The earlier grant of interest therefore could not be withdrawn by rectification, and the issue was answered in favour of the assessee.

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Issues: Whether interest granted to the assessee under section 214 of the Income-tax Act, 1961 could be rectified under section 154 when the entitlement to such interest was a debatable question.

Analysis: The assessee had paid advance tax, though beyond the prescribed dates, and interest under section 214 had initially been granted. The later withdrawal of that interest under section 154 depended on whether the payment qualified as advance tax and whether interest was payable under sections 207 to 213. The governing principle is that rectification under section 154 is confined to mistakes apparent from the record and cannot be used where the issue is debatable. Since the entitlement to interest on the facts was not free from doubt, the matter could not be reopened through rectification.

Conclusion: The order granting interest under section 214 could not be rectified under section 154. The answer to the referred question was in the affirmative and in favour of the assessee.

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