Sales tax refund interest starts six months after appellate orders, not from the later consequential assessment order.

Refund entitlement under the Andhra Pradesh General Sales Tax Act arose from the appellate orders and Tribunal orders, not from the later consequential order of the assessing authority. Section 33-B governed refunds becoming due from appellate or other proceedings, and section 33-F made the State liable to pay simple interest if the refund was not granted within six months from the date of such order. Section 24-A, which deals with consequential assessments or reassessments, did not postpone the refund or the start of interest. Interest therefore became payable from the day after expiry of six months from the Tribunal's order and the Appellate Deputy Commissioner's orders.

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Issues: Whether interest on the refund of sales tax was payable from the date immediately following the expiry of six months from the appellate orders, or only from the date of the consequential order passed by the assessing authority.

Analysis: The refund entitlement arose from the final orders passed by the appellate forum and the Tribunal, not from the later consequential order of the assessing authority. Section 33-B of the Andhra Pradesh General Sales Tax Act, 1954 provides for refund when it becomes due as a result of an appellate or other proceeding, and section 33-F makes the State liable to pay simple interest if the refund is not granted within six months from the date of such order. Section 24-A, which prescribes a time limit for consequential assessments or reassessments, does not govern refund claims or postpone the commencement of interest. The statutory right to interest therefore attached on the expiry of six months from the respective appellate orders.

Conclusion: Interest was payable from the date immediately following expiry of six months from the Tribunal's order and the Appellate Deputy Commissioner's orders, and not from the date of the consequential order of the assessing authority.

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