1. The following Question of law has been referred for the opinion of this Full Bench by a Division Beach of this Court : -
"Whether, in order to recover interest under S.8 (1 - A) of the U. P. Sales Tax Act, it is necessary for the Sales Tax Officer to make an assessment order in respect of the interest and to issue a notice of demand in respect of such interest"

2. In 1963 the Sales Tax (Second Amendment) Act was enforced. S.2 of this Act added sub-section (1 - A) to S.8 of the principal Act. That provision reads : -
"If the tax payable under sub-section (1) remains unpaid for six months after the expiry of the time specified in the notice of assessment and demand, or the commencement of the Uttar Pradesh Bikri Kar (Dwitiya Sanshodhan), Adhiniyam, 1963, whichever is later, then without prejudice to any other liability or penalty which the defaulter may in cons