Sales tax interest accrues only from actual demand after revised assessment, not from the return filing date.

Interest under sales tax law was held chargeable only from the date the assessed demand was actually raised on revised assessment, not from the date of filing of the return. The governing principle applied was that interest is compensatory and becomes payable only when the tax liability is quantified and made recoverable by demand notice, not at an earlier notional date. The settled position followed was that no interest can be imposed for any period before the demand is made, where the amount was ascertainable only upon assessment or revision.

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Issues: Whether interest under the sales tax law was chargeable from the date of filing of return or only from the date when the tax was actually demanded pursuant to the revised assessment.

Analysis: The question was treated as covered by prior binding authority holding that where tax liability is quantified only upon assessment or revision, interest cannot be fastened for any period anterior to the raising of the actual demand. The governing principle applied was that interest, being compensatory in nature, becomes payable only when the assessed amount becomes due and recoverable under a demand notice, not merely from the date of return or from an earlier notional date of liability. The decision followed the settled position that no interest can be imposed for a period before the demand is made.

Conclusion: Interest was not payable from the date of filing of the return and could be charged only from the date of the actual demand arising on the revised assessment, in favour of the assessee and against the Revenue.

Ratio Decidendi: Interest on tax becomes leviable only from the date the assessed demand is actually raised and not for any earlier period before the liability is quantified and made payable.

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