( 1 ) IN these petitions directed against levy of interest under the Sales Tax Act, the primary controversy centres round the interpretation of the expression "tax admittedly payable under the act" in Sub-section (1) of Section 8 introduced since 1975. Imposition of interest in fiscal statutes, in recent years is a normal feature to compensate the revenue for its loss due to delayed payments on one pretext or the other. In the Sales Tax Act it was introduced for the first time in 1964 when Sub-section (1-A) was added to Section 8 providing for payment of interest if tax assessed, reassessed or enhanced remained unpaid for six months from the date of service of notice of demand. While considering this provision the Honourable Supreme Court in Haji Lal mohd. Biri Works v. State of U. P. 1973 UPTC 690 (SC) observed : the above provision was apparently added with a view to tighten up the machinery for collection of sales tax and as a deterrent measure so that the dealers may not evade or delay the payment of tax.

( 2 ) WITH increase in rate of tax and growth in volume of business the tendency of withholding tax realised from customers on behalf of the Government, of whi