assessee is in appeal in respect of ITO's order under section 154 of Income-tax Act, 1961 ('the Act'), dated 7-11-1983 on its application dated 10- 1-1983 relating to assessment year 1980-81. In assessment order dated 24-9-1982, ITO had charged interest of Rs. 630 under section 139(8) of Act and Rs. 870 under section 215 /217 of Act. relevant extract from assessment order is as under: Rs. "Interest under section 139(8) 630 under section 215 /217 870" On account of rectification order amount of both interests got reduced to Rs. 570 and Rs. 790. Apart from change in quantum of interest payable in rectification application assessee had pointed out another mistake apparent from record in paragraph 2, quoted below, with which we are concerned: "2. Interest under sections 139(8) and 215 /217 has been charged without following proper procedure. High Court of Karnataka has held in its order dated 5-2-1981 that penal interest cannot be charged as matter of routine. ITO must issue notice to assessee proposing to charge interest and inviting his objection or explanation, if any. On assessee's failure to render satisfactory explanation, interest can be charged. extract from said judgment of High Court of Karnataka is enclosed herewith." judgment of Karnataka High Court in case of S. Govindaraju v. C I T [1982] 138 ITR 495 and extract from that was enclosed with application under section 154. ITO rejected plea of assessee in order under appeal. assessee's appeal before AAC has also been unsuccessful and, hence, this appeal to Tribunal. 2. We have heard rival submissions, and given deep thought to issue in hand. Shri. D. N. Sehgal, learned authorised representative of assessee, emphasised aspect basis himself on Karnataka High Court decision in S. Govindaraju's case (supra) that ITO should not have acted mechanically and should have applied his mind and followed procedure mentioned in Karnataka High Court decision, namely, he should have issued notice to assessee proposing to charge interest and invited his objections or explanation and thereafter considered explanation given. It was further stated that if that was found unsatisfactory then only interest could be charged. It was contended that for ITO's failure to follow proper procedure both penalties should be quashed. Attention was also invited to decision of this Bench in case of Suresh Chander Mehra (HUF) [IT Appeal No. 355 (Asr.) of 1983, dated 19-3-1984]. revenue, on other hand, relied on orders of authorities below and contended that there was no mistake apparent from record. 3. For deciding issue before us, we may begin by observing that issue has arisen on basis of application under section 154 dated 10-1- 1 9 8 3 moved by assessee pointing out certain mistakes apparent from record. We are concerned with mistake pointed out in paragraph 2 quoted above. It is first principle that in rectification proceedings decision will have to be made only on issue raised and not on any other issue, which might go i n favour of assessee and let him succeed in his request for rectification. Unfortunately for assessee there is conflict of opinion amongst High Courts on question of procedure to be followed by ITO for charging of interest. Allahabad High Court in Addl. CIT v. Saraya Distillery [1978] 115 ITR 34 has reiterated its opinion previously held: ".... For charging interest for default or shortfall in payment of advance tax due, Income-tax Officer is not required to pass any formal order. Under law he is required to calculate interest in manner provided under Act and Rules framed thereunder ...." (p. 37) Rule 46 of Income-tax Rules, 1962 ('the Rules'), was specifically mentioned before High Court. procedure that is laid down by Allahabad High Court is that ITO is required to calculate interest in manner provided under Act and Rules framed thereunder and nothing more and no formal order is required to be passed. In instant case, ITO has included amounts calculated of two types of interest in assessment order even. According to Allahabad High Court, this action of ITO would be enough and in accordance with law. decision of Karnataka High Court i n CIT v. Executors of Estate of Late H. H. Rajkuverba Dowager Maharani Saheb of Gondal [1978] 115 ITR 301 took different view from that of Allahabad High Court on point of passing of order and High Court held that: "Having regard to quasi-judicial nature of proceedings under section 217 , we are of opinion that order has to be passed by ITO to give effect to section 217 of Act." (p. 308) Madras High Court has noted in CIT v. City Palayacot Co. [1980] 122 ITR 430 at pages 445-446 that Kerala High Court has taken view similar to t h t of Karnataka High Court has taken view similar to that of Karnataka High Court in CIT v. Cochin-Malabar Estates Ltd. [1974] 97 ITR 466 and, therefore, there was conflict of opinion between High Courts. Madras High Court agreed with Kerala and Karnataka High Court decisions. If there is to be no formal order by ITO it is implied that there is no need for affording opportunity of being heard to assessee about why interest should not be charged; nor can procedure followed by him be held to be mere mechanical computation. In instant case, it may be pointed out that assessee in application has merely referred to procedure and not contended that denial of hearing of to assessee deprive assessee of his right for reduction or waiver or interest charged under appropriate rules of Rules and in this respect application under section 154 is different on facts from pleas raised in S. Govindaraju's case (supra). It is nowhere suggested that there was mistake apparent from record inasmuch as ITO failed to consider applicability of relevant rules for reduction or waiver of interest in Rules. jurisdiction as we have stated earlier is very restrictive jurisdiction in case of application for rectification under section 154 and it springs from and is confined to mistake pointed out in application. Viewing from this angle, it has to be held that there is no mistake apparent from record within scope of section 154. issue has become debatable one and Supreme Court decision in T. S. Balaram, ITO v. Volkart debatable one and Supreme Court decision in T. S. Balaram, ITO v. Volkart Bros. [1971] 82 ITR 50 will apply. We may also clarify that decision of Tribunal included in assessee's paper book in case of Suresh Chander Mehra (HUF) (supra) was not rendered in respect of order under section 154 and issue considered therein arose from assessment order and related to charging of interest under section 216 of Act, which is appealable section. In our view, that decision will be of no assistance when we are considering matter arising under section 154. 4. In view of above discussion, we uphold ITO's conclusion though for reasons given above and dismiss appeal of assessee. 5. appeal is dismissed. *** SHARMA TEXTILE v. INCOME TAX OFFICER