( 1 ) PETITIONER-FIRM manufactures "agarbathies". For purpose of sales tax assessment under the Andhra Pradesh General Sales Tax Act, 1957 (hereafter referred to as the act ) the authorities assessed the petitioner-firm for assessment year 1985-86 by order dated 15-2-1990. "agarbathies" were classified as "perfumes" which falls in Entry No. 36 of the First Schedule and accordingly was subjected to tax at the rate of 10%. The tax was levied accordingly and for belated payment of tax interest was also levied and recovered from the petitioner. Even for 1986-87 tax was levied at 10% on similar reasoning. Interest was also levied and recovered from the petitioner-firm for delayed payment of tax in 1990. The petitioner challenged the assessment order before this Court in writ petitions but the challenge failed when the writ petitions were dismissed on 29-9-1989. The petitioner went to Supreme Court against the said order. The petitioner also carried his appeal under the Act before the Deputy Commissioner, Guntur contending that the "agarbathies" do not fall under the entry "perfumes". The Supreme Court by its judgment dated 20-2-1997 reversed the judgment of this Court in batch of writ petitions and held that "agarbathies" cannot be classified as "perfume" and the levy of tax at 10% was held invalid and it was observed that tax at the rate of 5% at the general rate only could be recovered. In pursuance of this judgment, the Appellate Deputy Commissioner by his order dated 19-9-1997 in appeals which were pending before him held accordingly. Consequently a sum of six lakh rupees and more for assessment year 1985-86 and nine lakh ninety seven thousand rupees and odd for assessment year 1986-87 became refundable. The refunds were quantified by the authorities and consequently orders were passed on 29-9-1997 whereby the amount refundable was adjusted to the subsequent tax payment for the year 1997-98. This adjustment was done between 29-9-1997 to 20-12-1997. All these facts are undisputed.

( 2 ) THE petitioner-firm now contends that the respondents having recoveredand retained excess amount of sales tax are liable to pay interest at the rale of 2% per month on the excess amount collected and retained by the respondents. The petitioner made request for such interest by his letters dated 2-6-1997 and 2-2-1998. The petitioner was informed that the provisions of the act do not permit any such interest as claimed. It was pointed out that the only provision under the Act relating to payment of interest on refund, was contained in Section 33-F of the Act. The petitioner-firm s case did not fall under that provision and therefore the petitioner-firm s request was rejected.

( 3 ) THE contention of the learned Counsel for the petitioner-firm is that thepetitioner-firm is entitled to interest on ground of equity and equality of treatment between the parties. It is argued that the State whenever collects taxes from the assessee, it recovers interest if payment is delayed by the assessee. For the same reason, the assessee should also be paid interest if amount is not refunded to the assessee immediately.

( 4 ) WE have heard the learned Counsel for the petitioner-firm at length. It was not disputed that the petitioner has no statutory right as there is no provision in the Act which will entitle the petitioner-firm to make such claim of interest. The case is based wholly on grounds of equity and good conscience. In matters of Laws relating to taxation, the Courts have to construe, interpret and apply the law strictly in terms of the Statute. The argument that there is no bar in the Act to make such claim by the assessee is sufficient justification for the equitable claim, does not impress us. The Act has made provision for payment of interest in cases of refund only under circumstances covered by section 33-E and Section 33-F of the Act. Thus a specific provision is made in the Act as to when the assessee is entitled to interest. A spe