https://www.taxtmi.com/caselaws?id=168022 The appellate pre-deposit requirement under sales tax law was construed strictly: where the provision expressly required payment of tax and, where applicable, penalty before an appeal could be entertained, interest could not be added by implication. The deeming fiction treating interest as tax operated only for collection and recovery purposes, and did not expand the separate condition for hearing an appeal. The omission of any express reference to interest in the appeal provision was treated as deliberate, so the appellant was not required to deposit interest as a pre-condition for maintaining the appeal on merits. en-us Mon, 30 Jul 2012 00:00:00 +0530 Wed, 07 Jan 2015 09:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=168022 The appellate pre-deposit requirement under sales tax law was construed strictly: where the provision expressly required payment of tax and, where applicable, penalty before an appeal could be entertained, interest could not be added by implication. The deeming fiction treating interest as tax operated only for collection and recovery purposes, and did not expand the separate condition for hearing an appeal. The omission of any express reference to interest in the appeal provision was treated as deliberate, so the appellant was not required to deposit interest as a pre-condition for maintaining the appeal on merits. Case-Laws VAT and Sales Tax Mon, 30 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=168022