Pre-assessment interest on additional purchase tax liability cannot be charged before liability is quantified in assessment.

Interest on additional purchase tax liability was treated as accruing only after the liability was quantified in assessment, not from the date of the underlying transaction or return filing. The challenge to the purchase tax levy itself was not effectively pursued in light of binding precedent, leaving interest as the only live issue. On that basis, interest for the period before the assessment order could not be demanded, and relief was granted to the extent of deleting that pre-assessment interest.

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Issues: Whether interest could be levied for the period prior to passing of the assessment order.

Analysis: The challenge to the underlying purchase tax liability was not pressed effectively in view of binding precedent, and the only surviving controversy concerned interest. The scheme of the Act treated interest as arising in relation to the additional liability determined on assessment, not from the date of the underlying transaction or return filing. On that basis, interest could not be demanded for the period before assessment where the additional liability had not yet been quantified.

Conclusion: Interest for the period prior to the assessment order was not leviable, and relief was granted to that extent in favour of the petitioner.

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