Self-assessment tax liability: interest runs from the rule-based due date, and an interim stay does not cancel statutory penalty exposure.

Under the self-assessment scheme, tax had to be discharged within the rule-prescribed time, and "due date for payment" under Section 32(1) meant the return and payment date fixed by the Rules, not the date of final assessment. Interest therefore accrued from that due date, and the interim writ order only stayed recovery; it did not extinguish the statutory liability or create immunity from interest or penalty under Sections 53 and 60. The decision also noted that the prior constitutional challenge had already failed, and the cited authority on a different provision was inapplicable. The demand for interest and penalty was sustained.

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Issues: Whether interest under Section 32(1) of the Punjab Value Added Tax Act, 2005 and penalty under Sections 53 and 60 were leviable when tax was payable under the self-assessment scheme, and whether the interim order in the constitutional challenge postponed or negated such liability.

Analysis: The liability to pay tax under the Act was required to be discharged by self-assessment within the time prescribed under Section 26 and Rule 36 of the Punjab Value Added Tax Rules, 2005. The expression "due date for payment" in Section 32(1) was held to refer to the date fixed under the Rules for filing return and making payment, not the date of final assessment. Section 26(3) obliges payment of the full amount of tax due under the Act, and Section 26(4) also contemplates payment of interest where additional tax becomes payable on rectification of a return, showing that liability is not postponed until assessment is completed. The interim order passed in the writ proceedings merely suspended recovery; it did not extinguish the statutory liability or create a right contrary to the Act. The earlier challenge to the constitutional validity of Section 19 had also attained finality against the assessee, and the cited decision in J.K. Synthetics did not assist because it concerned a different provision.

Conclusion: Interest under Section 32(1) was payable from the due date fixed under the Rules, and the appellant was not absolved of liability to interest or penalty under Sections 53 and 60. The question was answered against the assessee and in favour of the Revenue.

Final Conclusion: The appeals failed and the demand of interest and penalty was sustained.

Ratio Decidendi: Under a self-assessment tax regime, statutory interest accrues from the rule-prescribed due date for payment, and an interim stay against recovery does not suspend or nullify the underlying tax liability or its consequential statutory incidence.

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