https://www.taxtmi.com/caselaws?id=3649 Interest under Section 18(3) of the Customs Act could not be levied on differential duty paid after finalisation of provisional assessments where those assessments were made before 13-7-2006. Section 18(3) is a substantive charging provision for interest on differential duty arising from final assessment, and it cannot operate retrospectively absent express legislative intent. The reference to the rate under Section 28AB does not make Section 28AB the source of the levy. The Board's clarification on the pari materia excise rule was treated as supporting this position, confirming that no interest is payable where provisional assessment predated the commencement of the provision. en-us Wed, 26 Dec 2007 00:00:00 +0530 Mon, 21 Apr 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=3649 Interest under Section 18(3) of the Customs Act could not be levied on differential duty paid after finalisation of provisional assessments where those assessments were made before 13-7-2006. Section 18(3) is a substantive charging provision for interest on differential duty arising from final assessment, and it cannot operate retrospectively absent express legislative intent. The reference to the rate under Section 28AB does not make Section 28AB the source of the levy. The Board's clarification on the pari materia excise rule was treated as supporting this position, confirming that no interest is payable where provisional assessment predated the commencement of the provision. Case-Laws Customs Wed, 26 Dec 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=3649