Interest on delayed tax payment requires express statutory authority; absent such a provision, the levy cannot be sustained.

Interest on delayed payment of tax is a substantive levy that can be imposed only when the taxing statute itself contains an express enabling provision. The Entry Tax Act, 1990 was treated as a self-contained enactment, and its provisions on assessment, payment, and recovery of unpaid tax or penalty did not authorise interest on belated payment of entry tax or penalty. Reliance on the General Sales Tax enactment was therefore misplaced because that law was not incorporated for imposing penal interest. The levy was consequently without authority of law and could not be sustained.

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Issues: Whether interest could be levied on belated payment of entry tax and penalty under the Entry Tax Act, 1990 in the absence of a substantive enabling provision.

Analysis: Interest on delayed tax payment is a matter of substantive law and can be imposed only when the taxing enactment contains a specific enabling provision authorising such levy. The Entry Tax Act, 1990 was treated as a stand-alone and self-contained enactment. Its provisions dealing with assessment, payment of tax, and recovery of unpaid tax or penalty did not contain any express authorisation to levy interest on delayed payment of tax or penalty. The reference to the General Sales Tax enactment was therefore held to be misplaced, since the Entry Tax Act did not draw upon that law for the purpose of imposing penal interest.

Conclusion: The levy of interest was authority of law and could not be sustained.

Ratio Decidendi: Interest on delayed payment of tax can be levied only when the taxing statute itself contains an express substantive provision authorising such levy.

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