Rectification cannot withdraw section 214 interest on a debatable issue; mistake apparent from record was absent.

Withdrawal of interest granted under section 214 through rectification under section 154 was not valid because the issue was debatable and not a mistake apparent from the record. The dispute concerned credit and consequential interest on advance-tax payment, and the tribunal noted that section 154 is limited to patent errors and cannot be used to reopen a matter or change a previously taken view on a controversial point. The rectification order was therefore unsustainable and was set aside in favour of the assessee.

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Issues: Whether the withdrawal of interest granted under section 214 by invoking section 154 was valid when the point involved was debatable and not free from difficulty.

Analysis: The dispute concerned credit and consequential interest on advance-tax payment. The matter was treated as one involving controversy and difficulty rather than an obvious error patent on the face of the record. Rectification under section 154 is confined to mistakes apparent from the record and does not extend to reopening a matter by changing a previously formed view on a debatable issue.

Conclusion: The rectification order was not sustainable and was set aside in favour of the assessee.

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