AJIT K. SENGUPTA, J. ( 1 ) IN this reference under Section 256 (2) of the Income-tax Act, 1961, for the assessment year 1981-82, the following question of law has been referred :"whether, on the facts and in the circumstances of the case, the Tribunal was justified in upholding the order of the Commissioner of Income-tax (Appeals) directing the Inspecting Assistant Commissioner to accept the rectification petition of the assessee and to allow the assessee interest under Section 214 of the Income-tax Act, 1961 ?" ( 2 ) THE brief facts of the case are that the assessee, Messrs. Orient Paper and Industries Ltd. , is a resident company and the assessment year involved is 1981-82 for which the accounting period ended on March 31, 1981. The income-tax assessment for the assessment year 1981-82 was completed under Section 143 (3) of the Income-tax Act, 1961, on February 20, 1984. Since the assessment in question resulted in a refund, the Assessing Officer granted interest under Section 214 to the assessee up to the date of assessment to the tune of Rs. 1,17,710. Therefore, the assessee filed a petition under Section 154 of the Income-tax Act, 1961, dated July 4, 1985, praying for the grant of interest under Section 214 ibid up to the date of the order giving effect to the appellate order. The Assessing Officer rejected the said petition under Section 154 of the Income-tax Act, 1961, filed by the assessee holding that interest under Section 214 ibid was correctly granted to the assessee on the amount by which the aggregate of advance tax paid exceeded the tax determined on regular assessment made under Section 143 (3) of the Act and, as such, there was no mistake apparent from record. ( 3 ) BEING aggrieved, the assessee brought the issue before the Commissioner of Income-tax (Appeals) and it was held by the Commissioner of Income-tax (Appeals) that the decision of this court in the case of Chloride India Ltd. v. CIT [1977] 106 ITR 38 has become the law of the territory under its jurisdiction. The Assessing Officer should have allowed interest under Section 214 of the Income-tax Act, 1961, in accordance with the principles laid down in the case of Chloride India Ltd. Since this has not been done, the action of the Assessing Officer has to be considered as a mistake apparent from the record. The Assessing Officer should have allowed interest under Section 214 of the Income-tax Act, 1961, in accordance with the principles laid down in the case of Chloride India Ltd. Since this has not been done, the action of the Assessing Officer has to be considered as a mistake apparent from the record. Thus, the Commissioner of Income-tax (Appeals) directed the Assessing Officer to accept the rectification petition of the assessee and allow interest under Section 214 in accordance with the principles laid down in the case of Chloride India Ltd. ( 4 ) CONTRARY to the decision of the Calcutta High Court in the said Chloride India Ltd. 's case [1977] 106 ITR 38, and also of the Rajasthan and Gujarat High Court, some High Courts, viz. , the Allahabad, Kerala, Punjab and Haryana, Andhra Pradesh and Bombay [fb] High Courts, have held that interest is payable only up to the date of the original assessment. The Department then agitated this issue before the Tribunal. The Tribunal, however, considering the order of the Commissioner of Income-tax (Appeals) in this respect endorsed his findings. ( 5 ) THE only question which has been agitated is whether any rectification proceedings under Section 154 of the Act can be accepted. It is no doubt true that so far as this court is concerned, the issue is settled by the Division Bench of this court in CIT v. Chloride India Ltd. [1990] 186 ITR 217. However, on the issue two conceivable views have been taken. Although the Rajasthan and the Gujarat High Courts have taken the same view as that of the Calcutta High Court, the Allahabad, Kerala, Punjab and Haryana and Andhra Pradesh High Courts have taken contrary views that the interest is payable only up to the date of the original assessment. The question is whether there is any divergence of judicial opinion or not. Our attention has not been drawn to the divergence of judicial opinion on the question as to the interpretation and scope of the words "original assessment". The Tribunal fell in error in directing the Assessing Officer to grant interest in a proceeding under Section 154 of the Income-tax Act. Our attention has not been drawn to the divergence of judicial opinion on the question as to the interpretation and scope of the words "original assessment". The Tribunal fell in error in directing the Assessing Officer to grant interest in a proceeding under Section 154 of the Income-tax Act. ( 6 ) THIS court in the case of V. R. Sonti v. CIT [1979] 117 ITR 838 has held that if there is a divergence of judicial opinion on a question of law or two conceivable views are possible on it, proceedings for rectification under Section 154 or under Section 254 (2) of the Income-tax Act, 1961, cannot be taken at all. It has also been held that when dealing with a rectification application, the authority should not look only at the decisions of the particular High Court under whose advisory jurisdiction it acts in order to find out whether there is any controversy on the question of law involved in the matter. As indicated above, several High Courts have taken contrary views and in view of the divergence of judicial opinion on a question of law, we are of the view that the Tribunal was not right in its conclusion. ( 7 ) WE, therefore, answer the question in this reference in the negative and in favour of the Revenue. There will be no order as to costs.