Interim tax payment and interest directions left disputed earlier interest period and penalty open for final hearing

At the interim stage, the High Court directed payment of the tax component and interest calculated from 28.03.2017, while allowing adjustment of amounts already paid and permitting further time on financial difficulty. The Committee's recommendations were accepted only for further consideration, and the question of interest for the period 2010 to 2017 was expressly left open for final hearing. No final adjudication was made on penalty or on the disputed earlier interest period, so the substantive liability remained unresolved.

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Issues: Whether the petitioners were to be directed, at the interim stage, to pay the tax component and interest, and whether the question of interest for the period 2010 to 2017 was finally decided.

Analysis: The order accepted the Committee's recommendations only for the purpose of further consideration and directed the petitioners to pay the tax amount and interest calculated from 28.03.2017 on or before 31.07.2019. It also permitted adjustment of amounts already paid and allowed petitioners to seek further time in case of financial difficulty. The order expressly deferred the question of interest for the period 2010 to 2017 to the final hearing stage.

Conclusion: No final adjudication on penalty or the disputed interest period was made; only interim payment directions were issued, and the substantive liability remained open for final hearing.

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