Instalment relief excluded for self-assessed tax interest; statutory interest on delayed payment accrues automatically and cannot be deferred.

Interest on belated payment of admitted self-assessed tax is an automatic statutory consequence under Section 50 and accrues on the unpaid amount. Section 80 permits instalment relief only for amounts due under the Act other than liabilities self-assessed in a return, so the Commissioner had no power to extend instalments to the interest component arising from delayed payment of such admitted tax. The exclusion in Section 80 therefore barred the request for instalment payment, and the challenge to the demand failed.

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Issues: Whether the Commissioner was justified in rejecting the petitioner's request to pay interest demanded on belated payment of admitted self-assessed tax in instalments under Section 80 read with Rule 158 of the Odisha Goods and Services Tax regime.

Analysis: The demand arose from delayed deposit of tax disclosed in self-assessed returns. Interest under Section 50 is a statutory and compensatory consequence of failure to pay tax within the prescribed time and accrues automatically on the unpaid amount. Section 80 empowers the Commissioner to allow instalments only in respect of amounts due under the Act other than amounts due as per liability self-assessed in a return. Since the liability in question was interest arising from belated payment of self-assessed tax, the claim fell within the exclusion built into Section 80. The statutory text left no scope to extend instalment relief to such liability.

Conclusion: The rejection of instalment relief was valid and the challenge to the demand failed.

Final Conclusion: Relief under the instalment mechanism was unavailable for the impugned liability, and the writ petition failed on merits.

Ratio Decidendi: Instalment payment under Section 80 is unavailable for amounts attributable to self-assessed liability in returns, and interest for belated payment of admitted tax is an automatic statutory consequence under Section 50.

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