The HC held that executive circulars are not binding on courts...

The HC held that executive circulars are not binding on courts and that liability for interest arises solely under Section 220(2) of the Act; the first s.156 demand lost effect when the First Appellate Authority allowed the Applicant's appeal and the Revenue refunded the deposit with interest, and the subsequent s.156 demand dated 07.09.1998 gave rise to interest from 07.10.1998. Consequently the Applicant was not liable to pay interest from the date of the initial demand, and the Revenue is entitled to compute and recover simple interest under s.220(2) from 07.10.1998 until payment.

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