ORDER :

A.K. Jayasankaran Nambiar, J.

As all these O.T. Revisions deal with a common issue, they are taken up together for consideration and disposed by this common order.

2. The State of Kerala, who is the petitioner in all these O.T. Revisions, has raised the following substantial questions of law:

(a) Whether on the facts and the circumstances of the case the Appellate Tribunal has erred in law in holding that even though the respondent has collected tax at the rate in excess of the rate permitted, the said collection cannot said to be excess collection, since the tax liability of the respondent is higher than the tax so collected?

(b) Whether in the facts and circumstances of the case the Appellate Tribunal ought to have held that in the case of collection of tax in excess of rate permitted the respondent has to pay the said excess collected tax with interest to the Government, even if the tax liability of the respondent is higher than the tax so collected?

3. The respondents/assessees in these Revisions had opted to pay tax at the compounded rate provided under Section 8(f) of the Kerala Value Added Tax Act [hereinafter referred to as the “KVAT Act”]. The assessment years for which