The assessee filed an appeal, which was dismissed on the ground that the admitted amount of tax had not been deposited. The view taken that the amount of tax had not been paid was based on the consideration that although the assessee had paid the tax admitted by him, but not the interest due thereon. The revising authority has taken the view that although interest becomes a part of the tax under section 8 (1-C), the requirements of section 9 (1) (a), which applies in the present case, are met in case the assessee deposits the tax admitted by him in his returns or before the assessing authority, and the failure to deposit the interest on the tax is not fatal to the entertainability of the appeal.

The view taken by the revising authority appears to be correct. Sri V. D. Singh, appearing on behalf of the department, strenuously contended that the tax, which has to be deposited by an assessee before filing an appeal is an amount which is equal to the tax plus interest accrued thereon. In support of this contention, he drew my attention to section 8 (1) and 8 (1-C ). These provisions may be extracted :

" 8. (1) The tax admittedly payable shall be deposited within the time