The assessee was a non-resident shipping company, represented by its agent at that point of time, who filed an option under section 172(7) to be assessed regularly under the provisions of the Act, before the expiry of the assessment year. The order of assessment was passed levying interest under section 234A, but not levying interest under sections 234B and 234C. Thereafter, noticing Circular No. 9 of 2001 dated July 9, 2001, a rectification order was passed levying interest under sections 234B and 234C. The order of rectification was set aside by the Commissioner (Appeals) and this was confirmed by the Tribunal. On appeal the Court held that the rectification was made on the basis of a decision of the Supreme Court which was the declared law even when the original order which was rectified was passed. Circular No. 730 dated December 14, 1995 had lost its significance and validity, on the Supreme Court authoritatively speaking on the provision under section 172(7) and the effect of the option exercised, in A. S. GLITTRE D/5 I/S GARONNE v. CIT (1997) 225 ITR 739 (SC) There was hence an error apparent on the face of the record. The order of rectification was valid.   (AY.1996 -97)