Self-assessed sales tax unpaid on time attracts automatic interest without fresh assessment or demand notice.

Where Additional Sales Tax was admitted in a self-assessment return, delayed remittance attracted interest under section 24(3) of the Tamil Nadu General Sales Tax Act, 1959 without any fresh assessment or demand notice. The Court treated the liability as arising from the returned turnover, not escaped turnover or a revised quantification, and held that tax due under the self-assessment scheme becomes recoverable in accordance with the return. Authorities concerning fresh assessment, revised demand, or appellate variation were distinguished. The later statutory framework under the Tamil Nadu Additional Sales Tax Act, 1970, as amended, reinforced the levy of interest on unpaid Additional Sales Tax. The challenge to the interest levy failed.

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Issues: Whether interest under section 24(3) of the Tamil Nadu General Sales Tax Act, 1959 was leviable on delayed remittance of Additional Sales Tax under a self-assessment scheme without a fresh assessment or demand notice.

Analysis: The liability to pay Additional Sales Tax arose on the turnover returned by the assessee, and the case did not involve escaped turnover or a fresh quantification of liability. Under the statutory scheme, section 24(3) applies to amounts remaining unpaid after the date specified for payment under section 24(1), and the corresponding rules show that, in a self-assessment context, tax on an admitted liability becomes due in accordance with the return and is recoverable without a demand notice. The Court distinguished authorities dealing with cases where liability depended on fresh assessment, revised demand, or appellate variation, and treated the present case as one of non-payment of an admitted statutory liability under self-assessment. The later statutory framework under the Tamil Nadu Additional Sales Tax Act, 1970, as amended, reinforced the levy of interest on unpaid Additional Sales Tax in line with section 24(3).

Conclusion: Interest under section 24(3) was payable and the challenge to the levy failed.

Ratio Decidendi: Where tax liability is admitted and payable under a self-assessment scheme, failure to remit it within the prescribed time attracts automatic interest under section 24(3) without the need for a fresh assessment or demand notice.

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