Statutory interest liability is confined to express provisions and cannot extend to tax quantified on rectification under section 17.

Interest liability arises only where the statute expressly creates it, and the scope of an interest provision is confined to the categories of tax quantification it specifically covers. On the facts, tax was quantified pursuant to rectification under section 17 of the Rajasthan Sales Tax Act, 1954, not under the type of order contemplated by section 11-B. Accordingly, section 11-B did not extend to the rectified demand, and interest could not be levied on that amount. The Tribunal's view that the assessee was not liable to pay interest was therefore upheld, and the revision was dismissed in favour of the assessee.

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Issues: Whether interest under section 11-B of the Rajasthan Sales Tax Act, 1954 could be levied on tax quantified pursuant to an order of rectification under section 17.

Analysis: Interest liability can arise only where the Act contains a specific provision creating that liability. Section 11-B, as amended, confined the levy of interest to cases where tax had been quantified in the manner contemplated by that provision. Where the quantification of tax was made under section 17, and not under the category of orders contemplated by section 11-B, the provision for interest did not extend to such demand. The Tribunal had therefore correctly held that the assessee was not liable to pay interest on the demand raised after rectification.

Conclusion: Interest under section 11-B was not leviable on tax quantified under section 17, and the revision was rightly dismissed in favour of the assessee.

Ratio Decidendi: Interest cannot be imposed unless the statute expressly creates that liability, and a provision conferring interest is confined to the specific categories of quantification expressly covered by it.

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