Interest on reassessed sales tax follows the deeming fiction under amended section 11-B until quantification.

Under the amended Rajasthan Sales Tax Act, interest on short-paid tax quantified in reassessment or rectification proceedings is chargeable from the date the tax is deemed payable under section 11-B(1)(f), not merely from the date of reassessment or demand. The provision creates a deeming fiction that extends interest up to the date of quantification, while section 11-B(2) applies only after quantification if the demanded amount is not paid within the notice period. Section 16-B(2) also supports levy of interest by reference to assessment, reassessment or rectification orders. Earlier authorities under the unamended law do not control the amended scheme.

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Issues: Whether, under the amended provisions of the Rajasthan Sales Tax Act, 1954, interest is payable on additional tax found due in reassessment or rectification proceedings from the date the tax is deemed payable, and not merely from the date of reassessment or demand.

Analysis: The amended scheme of section 11-B distinguishes between interest on tax not paid as per return and interest on tax quantified in assessment, reassessment or rectification proceedings. Section 11-B(1)(f) creates a legal fiction that, where tax is quantified and a shortfall is found, the difference is deemed to have been payable for the relevant period and interest runs up to the date of quantification. Section 11-B(2) then applies after quantification if the demanded amount is not paid within the time specified in the notice of demand. Section 16-B(2) also recognizes that interest may be levied with reference to assessment, reassessment or rectification orders, showing that liability is not confined to admitted tax shown in the return. The earlier unamended-law authorities did not govern the amended provision.

Conclusion: Interest is leviable on the quantified additional tax from the date it is deemed payable under section 11-B(1)(f) until quantification, and the Revenue's revision petitions succeed.

Ratio Decidendi: Under the amended section 11-B, interest on short-paid tax quantified in assessment or reassessment is chargeable by carrying the statutory deeming fiction to its logical end, with section 11-B(2) governing the post-quantification period after notice of demand.

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