JUDGMENT

H.L. Dattu, J. —

1) This appeal is directed against the Judgment and Order passed by the High Court of Calcutta in W.P.T.T. No. 102 of 2000 dated 14.09.2001.

2) The issues which require our consideration and decision in this appeal are: the meaning of the expression ‘Investment’ for the purpose of notification issued by the State of West Bengal under West Bengal Sales Tax Act and the corresponding Rules; the construction and interpretation of an exemption notification; and whether the interest is payable on tax only on quantification of tax by way of assessment under the Act or for any period prior to that.

3) The material facts are :-

The assessee is M/s Tulip Products Co., a partnership firm having a fruit processing unit at 37, Imjad Ali Lane, Calcutta. It is a small scale industrial unit. The Unit is engaged in manufacturing juice, jelly, jam etc. The unit was registered as a dealer under the Bengal Finance (Sales Tax) Act, 1941 (hereinafter to be referred as “the Act, 1941”), the West Bengal Sales Tax Act, 1954 (hereinafter to be referred as “the Act, 1954”), and was later registered under the West Bengal Sales Tax Act, 1994 (hereinafter to be referred as “the Act, 199