https://www.taxtmi.com/caselaws?id=175460 Section 20(5) of the Punjab General Sales Tax Act required deposit of tax or penalty, as the case may be, before an appeal could be entertained; it did not expressly require payment of interest. The statutory deeming fiction treating interest as tax for recovery purposes could not be extended to the separate appellate-admission provision, and such a restrictive precondition had to be construed strictly. Accordingly, insistence on deposit of interest as a condition precedent for hearing the appeal was held illegal, and the assessee was entitled to have the appeal heard on merits after complying with the balance tax requirement. en-us Tue, 22 Nov 1994 00:00:00 +0530 Mon, 23 Nov 2015 10:41:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175460 Section 20(5) of the Punjab General Sales Tax Act required deposit of tax or penalty, as the case may be, before an appeal could be entertained; it did not expressly require payment of interest. The statutory deeming fiction treating interest as tax for recovery purposes could not be extended to the separate appellate-admission provision, and such a restrictive precondition had to be construed strictly. Accordingly, insistence on deposit of interest as a condition precedent for hearing the appeal was held illegal, and the assessee was entitled to have the appeal heard on merits after complying with the balance tax requirement. Case-Laws VAT and Sales Tax Tue, 22 Nov 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175460