Interest on belated tax payment applies automatically even when tax is admitted only in a revised return.

Interest under section 24(3) of the Tamil Nadu General Sales Tax Act, 1959 is attracted on belated payment of admitted tax, including tax first disclosed in a revised return filed after the due date. Where the assessee initially claimed exemption, omitted the turnover, and later paid the liability only after it was established, section 24(1) required payment within the prescribed time and section 24(3) mandated interest for default. The liability to interest arose automatically on delay and did not depend on the assessee's bona fides or the voluntariness of the revised return. A Supreme Court decision relied on by the assessee was held to concern a different factual situation and was inapplicable.

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Issues: Whether interest under section 24(3) of the Tamil Nadu General Sales Tax Act, 1959 was leviable on delayed payment of tax admitted only in a revised return.

Analysis: The assessee had originally claimed exemption and did not offer the relevant turnover. After the liability was demonstrated and accepted, tax was paid only through revised returns filed long after the due dates. Under section 24(1), tax payable under the Act must be paid in the prescribed manner and within the prescribed time, and section 24(3) mandates interest on belated payment. The liability to pay interest arises automatically on default in payment of admitted tax and does not depend on the assessee's bona fides or on whether the return was later revised voluntarily. The reliance on the Supreme Court decision concerning a different factual matrix was held to be inapplicable.

Conclusion: Interest under section 24(3) was correctly levied, and the challenge to the demand failed.

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