Statutory interest on deferred sales tax survives absent express waiver, and rehabilitation scheme silence does not extinguish liability.

Interest remained payable on deferred sales tax because the rehabilitation scheme granted only deferment and contained no express waiver of statutory interest. The memorandum of understanding likewise referred only to reliefs and concessions for a sick industrial undertaking and did not undertake to waive interest on the deferred tax. Under the sales tax law, extension of time for payment attracted interest as a statutory consequence, and the special rehabilitation scheme displaced that liability only to the extent of an actual inconsistency. The later government order was treated as a clarification of payment mechanics, not as a waiver. The statutory interest liability therefore continued.

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Issues: Whether interest was payable on sales tax whose payment had been deferred under the government orders and the BIFR-sanctioned rehabilitation scheme, and whether the scheme or memorandum of understanding contained any waiver of the statutory liability to pay such interest.

Analysis: The sanctioned scheme provided for deferment of sales tax liabilities, but it did not contain any express waiver of interest. The memorandum of understanding also only assured the grant of reliefs and concessions available to sick industrial undertakings and did not undertake that interest on deferred sales tax would be waived. Under the sales tax law, where time for payment is extended, interest becomes payable as a statutory consequence. The scheme under the special rehabilitation statute could prevail over other laws only to the extent of an actual inconsistency, but silence on waiver could not be read as an implied exclusion of the statutory interest liability. The Court also treated the later government order as a clarification of the manner of payment, not as a waiver of interest.

Conclusion: The appellants remained liable to pay interest on the deferred sales tax, and the statutory liability was not waived by the scheme, the memorandum of understanding, or the government orders.

Ratio Decidendi: A statutory interest liability on deferred tax can be displaced only by an express waiver; mere deferment of tax payment or silence in a rehabilitation scheme does not extinguish the obligation to pay interest under the tax statute.

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