Interest on revised tax demand runs from the original due date, not from the revisional order quantifying liability.

Interest on additional tax demand under the Haryana Value Added Tax Act, 2003 accrues from the date the tax ought to have been paid, because tax found payable in revision is treated as having been due when the liability originally arose. The later revisional order only quantifies the existing liability and does not defer the interest obligation. Applying this principle, the Court rejected the contention that interest could run only from the date of the revisional order and accepted the Revenue's position on commencement of interest for the additional demand.

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Issues: Whether interest on additional tax demand created by the revisional authority is leviable only from the date of the revisional order, or from an earlier date when the tax liability arose.

Analysis: The appeals turned on Section 14(6) of the Haryana Value Added Tax Act, 2003, under which interest is chargeable when tax is not paid in accordance with the Act and the rules. The Court followed its earlier Division Bench view that the additional tax determined on revision represents tax that was always due from the date the liability arose, and that the liability to pay interest is not postponed merely because the revisional order quantifies the demand later. On the admitted facts, the controversy was confined to the commencement date for interest on the additional demand.

Conclusion: Interest on the additional tax demand is leviable from the date when the tax ought to have been paid and not merely from the date of the revisional order. The issue is decided in favour of the Revenue and against the assessees.

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