Refund interest runs from the date of deposit, and contrary circular restrictions cannot override the statute.

Refundable tax under section 23(2) of the Rajasthan Sales Tax Act, 1954 carries interest from the date of deposit until refund on the plain statutory wording. The provision fixes both the rate and the commencement of interest, so a later starting point or a minimum one-year deposit period cannot be read into it. Circulars and an order restricting interest contrary to that text were inconsistent with the Act and therefore invalid. The matter was remitted for fresh determination in accordance with law.

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Issues: Whether interest on refundable tax under section 23(2) of the Rajasthan Sales Tax Act, 1954 accrues from the date of deposit till refund, and whether circulars and the order restricting interest to a later date and minimum one-year period are valid.

Analysis: Section 23(2) uses clear language that the refundable amount shall carry interest with effect from the date of deposit. The provision fixes both the rate and the starting point of interest, and does not support reading in any restriction that interest begins only from the date of substitution of the provision or only after the amount remains in deposit for one year. Applying the plain and ordinary meaning of the statutory words, the circulars and the order that limited interest contrary to the statutory text were inconsistent with the Act.

Conclusion: The interest payable on refund runs from the date of deposit until refund, and the contrary circulars and order were invalid.

Final Conclusion: The assessee obtained relief on the interpretation of the refund-interest provision, and the matter was sent back for fresh determination in accordance with law.

Ratio Decidendi: When the statutory language expressly provides that refundable tax shall carry interest with effect from the date of deposit, the provision must be given its plain meaning and administrative circulars cannot curtail that entitlement by introducing a later starting point or a minimum period not found in the statute.

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