Rectification cannot withdraw advance-tax interest where entitlement turns on a debatable legal issue.

Rectification power under section 154 cannot be used to withdraw interest granted under section 214 where the dispute turns on whether delayed advance-tax instalments affect entitlement. The point was not an obvious or patent mistake; it depended on competing judicial views on the treatment of advance-tax payments and the resulting interest. Because a debatable issue falls outside the narrow scope of rectification, the attempted withdrawal of interest was not sustainable.

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Issues: Whether the Assessing Officer could invoke rectification powers to withdraw interest allowed under section 214 on the ground that the advance-tax instalments had been paid after the due dates and the question was debatable.

Analysis: The adjustment sought to be made involved the treatment of advance-tax instalments and the consequent entitlement to interest under section 214. The controversy was not one of an obvious or patent mistake; it depended on the competing judicial views on whether such interest could be withdrawn by treating the delayed instalments as outside the permissible advance-tax payment scheme. A matter that is debatable in law does not fall within the narrow scope of rectification.

Conclusion: The rectification under section 154 was incompetent because the issue was debatable, and the withdrawal of interest under section 214 could not be sustained.

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