Statutory interest limits bar interest on delayed interest under Central Excise law; no implied liability arises.

Interest in tax matters is payable only where the statute expressly creates that liability. Under the Central Excise Act and Rules, no provision authorises interest on delayed payment of interest: Section 11BB is limited to interest on delayed refund of duty, and Rule 9B concerns provisional assessment only. The Tribunal could not infer a further liability or invoke any inherent power to grant it. The claim for interest on delayed payment of interest therefore fails.

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Issues: Whether interest on delayed payment of interest is permissible under the Central Excise Act and the Rules.

Analysis: The allowance of interest in tax matters depends on an express statutory provision. The Court distinguished authorities under the Income-tax Act, where specific provisions existed, and held that the Central Excise Act contained no corresponding provision creating a right to interest on delayed payment of interest. Section 11BB provided for interest on delayed refund of duty, and Rule 9B dealt with provisional assessment, but neither authorised a further claim for interest on the delayed payment of interest. The Tribunal could not supply such a liability by implication or exercise any inherent power to award it.

Conclusion: Interest on delayed payment of interest is not permissible under the Central Excise Act and the Rules, and the claim fails.

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