assessee had made advance tax payments of Rs. 10,000 on 16-3- 1978 and Rs. 60 on 31-3-1978 after statutory due date for payment of installment. ITO by his order dated 19-11-1982 had allowed interest of Rs. 28,345 under section 214 of Income-tax Act, 1961 ('the Act'). Subsequently, he passed order dated 24-1-1984 under section 154 of Act rectifying his earlier order by withdrawing interest allowed under section 214. In doing so, he followed decision of Andhra Pradesh High Court in case of Kangundi Industrial Works (P.) Ltd. v. ITO [1980] 121 ITR 339. Against said order assessee appealed to Commissioner (Appeals). He cancelled order dated 24-1-1984 made under section 154 on ground that issue is debatable one and there is no mistake apparent from record which could be rectified under section 154. Against said order, revenue has preferred this appeal. 2. learned departmental representative kly urged that as advance tax has been paid after due dates for payment of installment, no interest under section 214 could be allowed in view of decision of Andhra Pradesh High Court in Kangundi Industrial Works (P.) Ltd.'s case (supra). In view of above decision, ITO had jurisdiction to pass order under section 154 and he was bound to do so. 3. We have considered submissions of learned departmental representative. question for consideration is whether provisions of section 154 could be invoked in instant case. assessee has made advance tax payments after due dates but within financial year. Andhra Pradesh High Court in case of Kangundi Industrial Works (P.) Ltd. (supra) has held that if advance tax is paid after due dates but within financial year, assessee is not entitled to interest under section 214. Contrary view has been taken by Gujarat High Court in case of Chandrakant Damodardas v. ITO [1980] 123 ITR 748 and also by Madras High Court, Madhya Pradesh High Court and Punjab and Haryana High Court. In view of conflict between various High Courts, issue whether assessee is entitled to interest under section 214 when advance tax was paid after due dates is debatable issue as there are two views. As held by Supreme Court in T.S. Balaram, ITO v. Volkart Bros. [1971] 82 ITR 50, mistake apparent on record must be obvious and patent mistake and decision on debatable point of law is not mistake apparent from record. 4. contention urged by learned departmental representative is that since decision of Andhra Pradesh High Court in case of Kangundi Industrial Works (P.) Ltd. (supra) is binding on revenue authorities within State of Andhra Pradesh, ITO was justified in invoking provisions of section 154. No doubt, this contention is supported by decision of Allahabad High Court in Omega Sports & Radio Works v. CIT [1982] 134 ITR 28, Punjab and Haryana High Court in CIT v. Mohan Lal Kansal [1978] 114 ITR 583 and Gujarat High Court in CIT v. Ramjibhai Hirjibhai & Sons [1977] 110 ITR 411. But contrary view has been taken by Calcutta High Court in V.R. Sonti v. CIT [1979] 117 ITR 838 wherein it was held as under: "...It is also not law that ITO or appellate authorities under Income-tax Act for purposes of rectification application should only look at decisions of particular High Court under whose advisory jurisdiction it acts in order to find out whether that High Court has taken different views on question of law involved before it. They must consider decisions of all High Courts and if there is divergence of judicial opinion on question of law or two conceivable opinions are possible on it, they must hold that mistake is not apparent from record...." (p. 841) There is no decision of Andhra Pradesh High Court on this aspect. When two views are possible, view favorable to assessee should be adopted as held by Supreme Court in CIT v. Vegetable Products Ltd. [1973] 88 ITR 192. 5. In view of conflicting decisions, we are of view that issue involved in this case is debatable one and there is no mistake apparent which could be rectified by invoking section 154. Thus, Commissioner (Appeals) was justified in cancelling order dated 24-1-1984 made by ITO under section 154. 6. In result, appeal fails and is dismissed. *** INCOME TAX OFFICER v. SETTY PHARMACEUTICALS AND BIOLOGICAL SCIENCES