Karnataka High Court
M/S Marico Industries Ltd vs State Of Karnataka on 24 April, 2026
Author: S.G.Pandit
Bench: S.G.Pandit
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STRP No. 3 of 2020
Reserved on : 09.04.2026
Pronounced on : 24.04.2026
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 24TH DAY OF APRIL, 2026
PRESENT
THE HON'BLE MR. JUSTICE S.G.PANDIT
AND
THE HON'BLE MR. JUSTICE K. V. ARAVIND
SALES TAX REVISION PETITION No. 3 OF 2020
BETWEEN:
1. M/S MARICO INDUSTRIES LTD.,
MYSORE DEVIATION ROAD,
NEAR MINERVA MILLS,
BENGALURU-560023,
(NOW M/S MARICO LTD.,
MAKALI VILLAGE, SY No.10,
DASANAPURA HOBLI, BANGALORE,
BENGALURU(BANGALORE) NORTH,
KARNATAKA, 562162.
REPRESENTED BY ITS
Digitally
signed by AUTHORISED SIGNATORY,
VINUTHA B S MR. BHART PADGULEKAR,
Location: AGED ABOUT 55 YEARS,
High Court of S/O MR. NARAYAN PADGULEKAR.
Karnataka ...PETITIONER
(BY SRI THIRUMALESH M., ADVOCATE)
AND:
1. STATE OF KARNATAKA,
REPRESENTED BY PRINCIPAL
SECRETARY TO GOVERNMENT,
FINANCE DEPARTMENT,
GOVERNMENT OF KARNATAKA,
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VIDHANA SOUDHA,
BENGALURU-560001.
2. COMMISSIONER OF COMMERCIAL TAXES
KARNATAKA,
VANIJYA THERIGE KARYALAYA,
GANDHINAGAR,
BENGALURU-560009.
3. JOINT COMMISSIONER OF COMMERCIAL
TAXES(APPEALS)-2, 2ND FLOOR,
TTMC BUILDING, SHANTINAGAR,
BENGALURU-560027.
4. DEPUTY COMMISSIONER OF COMMERCIAL
TAXES(AUDIT AND REC)-2.8, DVO-2,
VANIJYA THERIGE KARYALAYA-2,
KORAMANGALA,
BENGALURU-560047.
...RESPONDENTS
(BY SRI ADITYA VIKRAM BHAT, AGA FOR R1 TO R4)
THIS STRP IS FILED UNDER SECTION 65(1) OF THE
KARNATAKA VALUE ADDED TAX ACT,2003, AGAINST THE
ORDER DATED 24.06.2019 PASSED IN ST RECTIFICATION
APPLICATION No.05 TO 07/2018 (IN STA Nos. 304 TO
306/2016) ON THE FILE OF THE KARNATAKA APPELLATE
TRIBUNAL AT BANGALORE, REJECTING THE APPLICATIONS
FILED FOR RECTIFICATION OF THE COMBINED JUDGMENT
PASSED BY THIS TRIBUNAL IN STA.No.304 TO 306/2016
DATED 25.01.2018 DISMISSING THE APPEALS FILED BY THE
APPELLANT AGAINST THE COMBINED APPELLATE ORDER
PASSED BY JCCT (APPEALS)-2, BENGALURU IN KST AP Nos.1
TO 3/12-13 DATED 22.12.2015.
THIS PETITION HAVING BEEN HEARD AND RESERVED
FOR JUDGMENT, COMING ON FOR PRONOUNCEMENT THIS
DAY, K.V. ARAVIND J., DELIVERED THE FOLLOWING:-
CORAM: HON'BLE MR. JUSTICE S.G.PANDIT
and
HON'BLE MR. JUSTICE K. V. ARAVIND
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C.A.V. ORDER
(PER: HON'BLE MR. JUSTICE K. V. ARAVIND)
Heard Sri. M. Thirumalesh, learned counsel for the
petitioner-Assessee and Sri. Aditya Vikram Bhat, learned
Additional Government Advocate for respondent Nos.1 to 4-
Revenue.
2. This Sales Tax Revision Petition is filed under Section
23(1) of the Karnataka Sales Tax Act, 1957 (for short, "the KST
Act"), by the dealer, calling in question the order passed by the
Karnataka Appellate Tribunal, Bengaluru (for short "the
Tribunal"), in ST Rectification Application Nos.05 to 07/2018 (in
STA Nos.304 to 306/ 2016), dated 24.06.2019.
3. The facts, in brief, are that the petitioner is a dealer
registered under the Karnataka Sales Tax Act, 1957 (for short,
"the KST Act"), and is engaged in the business of edible
coconut oil and coconut hair oil under the brand names
"Parachute", "Oil of Malabar", "Parachute Jasmine" and "Hair
and Care". The assessment orders for the assessment years
2002-03, 2003-04 and 2004-05 were passed levying tax on
the sale of coconut oil sold under brand names by applying Sl.
No.17-A of Part 'C' of the Second Schedule at the rate of 20%.
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3.1 The said Entry 17-A was challenged by the petitioner in
Writ Petition No.28125/2002, contending that it was
discriminatory and violative of Articles 14 and 16 of the
Constitution of India. The writ petition was allowed and the
amendment was struck down. However, the orders of
assessment were not set aside in the said writ proceedings.
3.2 The order passed in the writ petition was challenged in
Writ Appeal No.649/2006. The Division Bench, by order dated
15.12.2009, reported in 2011 (70) KLJ 93, set aside the order
of the learned Single Judge and upheld the validity of the
amendment. The Division Bench, however, directed the
Revenue to consider the case of the assessee having regard to
the distinction between sale of coconut oil as pure coconut oil
and as hair oil.
3.3 Pursuant thereto, the petitioner filed an application dated
18.01.2010 seeking rectification of the assessment order in
conformity with the judgment of the Division Bench. The said
application was not rejected within a period of 60 days and,
therefore, it is the case of the petitioner that the same stood
deemed to have been allowed in terms of the proviso to Section
25-A(1) of the KST Act.
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3.4 According to the petitioner, the refund ought to have
been granted within 90 days from the deemed date. The
deemed date is stated to be 22.03.2010 and the expiry of 90
days under Section 13-A of the KST Act is stated to be
22.06.2010. However, the adjudicating authority passed an
order of rectification on 08.04.2010.
3.5 The said order of rectification was set aside by the Joint
Commissioner of Commercial Taxes in exercise of powers under
Section 21(2) of the KST Act, by order dated 14.01.2011, and
the Assessing Authority was directed to pass fresh orders in the
light of the judgment of the Division Bench of this Court.
Pursuant thereto, the Assessing Authority passed a fresh order
on 16.08.2011. It is stated that a refund notice was issued on
20.08.2011.
3.6 The fresh assessment order dated 16.08.2011, along with
the refund order, was challenged before the Joint Commissioner
of Commercial Taxes (Appeals), and the appeal came to be
dismissed on 17.12.2011. Thereafter, a pay order was issued
on 09.01.2012. It is further stated that the request for grant of
interest was rejected on 17.07.2012. The said order rejecting
the claim for interest was challenged before the Tribunal in STA
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Nos. 304, 305 and 306/2016. The Tribunal, by order dated
25.01.2018, rejected the appeals.
3.7 The petitioner thereafter filed ST Rectification Application
Nos.05 to 07/2018 under Section 63(9)(a) of the Karnataka
Value Added Tax Act, 2003 (for short, "the KVAT Act") before
the Tribunal, which came to be rejected by order dated
24.06.2019.
4. Sri M. Thirumalesh, learned counsel appearing for the
petitioner, submits that the assessment orders were passed
levying tax at the rate of 20%. The assessment order for the
assessment year 2002-03 is dated 20.08.2003, for the
assessment year 2003-04 is dated 23.06.2004, and for the
assessment year 2004-05 is dated 12.04.2005. It is submitted
that the petitioner had challenged the constitutional validity of
the amendment imposing tax at 20%. The learned Single Judge
allowed the writ petition and quashed the amendment.
However, in the appeal preferred by the State, the Division
Bench set aside the order of the learned Single Judge while
upholding the validity of the amendment, and clarified the legal
position.
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4.1 It is further submitted that the petitioner filed an
application for rectification on 18.01.2010 seeking modification
of the assessment orders in conformity with the judgment of
the Division Bench of this Court. It is contended that, in terms
of the second proviso to Section 25-A(1) of the KST Act, such
an application cannot be rejected after the expiry of 60 days,
and consequently, the same is deemed to have been allowed.
4.2 Learned counsel submits that, in terms of Section 13-A of
the KST Act, if the refund is not granted within 90 days, the
petitioner would be entitled to interest at the rate of 6% per
annum for the period of delay. It is submitted that the
rectification application is to be reckoned from 22.01.2010, the
deemed date of rectification is 22.03.2010, and the period of
90 days expired on 22.06.2010. However, the refund was
granted only on 09.01.2012. It is therefore contended that
there is a delay of one year, six months and eighteen days, for
which the petitioner is entitled to interest at the rate of 6% per
annum.
4.3 Learned counsel for the petitioner submits that the order
of rectification dated 08.04.2010 is contrary to the proviso to
Section 25-A(1) of the KST Act. It is contended that, in the
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absence of a valid application, no rectification could have been
undertaken. It is further submitted that the Suo Motu
Revisional Authority has set aside the said order of rectification,
holding the same to be without jurisdiction, and directed a
fresh assessment. Pursuant to the order of the Suo Motu
Revisional Authority, a fresh assessment was made, against
which a refund came to be issued.
4.4 Learned counsel submits that the challenge to the said
fresh assessment order, as well as the refund order, was
rejected, however, in view of the proviso to Section 25-A(1) of
the KST Act, all consequential proceedings subsequent to
08.04.2010 are rendered invalid and non est in the eye of law.
It is further contended that, though the Tribunal has not denied
the entitlement of the petitioner to interest, it has erred in
computing the relevant period. Accordingly, it is submitted that
the petitioner is entitled to interest on the refund for the
delayed period from 22.06.2010 to 09.01.2012.
4.5 Learned counsel for the petitioner, in support of his
submissions, has placed reliance on the judgment of a Co-
ordinate Bench of this Court in Wipro Limited, Infotech
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Group, Belagola Industrial Area, Metagalli, Mysore v.
State of Karnataka, reported in 2021 (99) KGST L.J. 701.
5. Per contra, learned AGA appearing for the respondents
submits that the order of the Division Bench dated 15.12.2009
was communicated to the Assessing Authority on 23.03.2010.
Taking note of the said judgment, the rectification order dated
08.04.2010 came to be passed. It is contended that the
authorities are not precluded from passing more than one
rectification order. Even assuming that the rectification
application dated 18.01.2010 is deemed to have been allowed,
the same would not disentitle the authorities from passing a
subsequent rectification order in accordance with law.
5.1 It is further submitted that, by the revisional order dated
14.01.2011, the rectification order dated 08.04.2010 was set
aside, with a direction to the Assessing Authority to pass a
fresh assessment. Pursuant thereto, a fresh assessment order
was passed and refund was issued. Learned AGA submits that
the appeal challenging the fresh assessment order as well as
the refund order came to be dismissed by the appellate
authority by order dated 17.12.2011, and the said order has
attained finality, as the same has not been challenged further.
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5.2 It is further submitted that, while considering the
challenge to the order rejecting the request for interest, the
Tribunal, by its order dated 25.01.2018, rejected the appeals
by holding that the relevant period is to be reckoned from
23.03.2010, i.e., the date on which the copy of the judgment of
the Division Bench was made available to the Assessing
Authority. It is therefore contended that the impugned order
rejecting the rectification application by order dated 24.06.2019
is justified. It is also submitted that, in the absence of a
challenge to the main order dated 25.01.2018, the order
rejecting the rectification application cannot be independently
assailed.
6. We have considered the submissions made by learned
counsel for the parties and perused the appeal papers.
7. This petition was admitted, by order dated 12.07.2021, to
consider the following substantial questions of law:
"i. Whether in the facts and circumstances of the
case of the petitioner, the Tribunal did not
commit serious error of law in having
pronounced the decision as in paragraph 35 of
the impugned order making an unlawful
turnaround and departure from own findings of
facts and law brought on record of paragraph 6
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of the impugned order by which the
rectification applications filed by the petitioner
in ST Retfn. No.5-7/2018 were ordered for
admission?
ii. Whether in the facts and circumstances of the
case of the petitioner, the Tribunal did not
commit a serious error of law in having
pronounced decision that the petitioner did not
make out sufficient grounds either factually or
legally for interference with the judgment
passed in STA. No.304-306/2016 it being
diametrically opposite of the reiterated recitals
of the Tribunal itself in all the preceding
paragraphs of the impugned order?"
8. The Assessing Authority completed the assessments on
20.08.2003 for the assessment year 2002-03, on 23.06.2004
for the assessment year 2003-04, and on 12.04.2005 for the
assessment year 2004-05. In the said assessments, tax at the
rate of 20% was levied. The petitioner challenged Entry 17-A in
Part 'C' of the Second Schedule to the KST Act by filing Writ
Petition No.28125/2002. The learned Single Judge, while
allowing the writ petition, declared the said entry as
unconstitutional.
8.1 Aggrieved thereby, the State preferred Writ Appeal
No.649/2006 before the Division Bench. The Division Bench,
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while upholding the constitutional validity of the said entry,
held as under:
"7. Having seen the material produced before us and
also considering that even a coconut oil manufactured
by a particular industry cannot be sold without a brand
name, it would be difficult for us to accept the
arguments advanced by the learned Government
Advocate to say that any coconut oil sold under a brand
name either in sachet or bottle has to be treated as a
toilet article. We refuse to accept the arguments of the
Government Advocate to treat the coconut oil sold in a
brand name either in sachet or bottle as a toilet article.
By looking into the ingredients of the coconut oil sold by
two different companies, it is clear it is only a pure
coconut oil and neither meant as edible oil nor as hair
oil. But the bottle produced by the respondent--
assessee of Parachute company has got two brand
names, one is sold as a pure coconut oil and another is
a coconut hair oil. The ingredients of the hair oil sold
under the name of Parachute has got a different
ingredients than the one manufactured and sold by the
same company as 100 per cent pure coconut oil.
Considering these aspects, we are of the opinion that
the learned judge has not taken into account distinction
between the hair oil and edible oil. Since this aspect has
not been considered, we are of the view the learned
judge has committed an error in granting a relief to the
assessee in declaring the amendment as
unconstitutional in violative of article 14 of the
Constitution of India.
8. Considering the facts and background of the
amendment brought in, we are of the view that
whenever coconut oil is manufactured and sold as hair
oil, the same would attract tax at higher rate of 15 per
cent and 20 per cent as per the amendment brought to
the Karnataka Sales tax Act, and coconut oil sold as
pure coconut oil, as a brand name would attract only
four per cent as the same can be used as an edible oil
not exclusively as a toilet articles. In view of this
distinction, we allow this appeal."
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8.2 The petitioner filed a rectification application dated
18.01.2010 seeking rectification of the aforesaid assessment
orders in the light of the law declared by the Division Bench.
The said applications were received in the office of the Deputy
Commissioner of Commercial Taxes, Bangalore, on 22.01.2010.
The application enclosed a copy of the judgment of the Division
Bench as well as copies of the original assessment orders
sought to be rectified.
8.3 The rectification of mistakes is governed by Section 25-A
of the KST Act, which reads as under:
"25A. Rectification of mistakes.-(1) With a view to
rectifying any mistake apparent from the record, the
assessing authority, appellate authority or revising
authority, may, at any time, within five years from the
date of an order passed by it, amend such order:
Provided that an amendment which has the effect of
enhancing an assessment or otherwise increasing the
liability of the assessee shall not be made unless the
assessing authority, appellate authority or revising
authority, as the case may be, has given notice to the
assessee of its intention to do so and has allowed the
assessee a reasonable opportunity of being heard.
Provided further that where an application is made by
an assessee for rectification of any mistake in an order,
as being apparent from the record and, such application
has not been rejected by the assessing authority within
sixty days from the date of receipt of the application,
the order shall be deemed to have been amended
rectifying such mistake.
(2) Where an order has been considered and decided in
any proceedings by way of appeal or revision relating to
an order referred to in sub-section (1), the authority
passing such order may, notwithstanding anything
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contained in any law for the time being in force, amend
the order under that sub-section in relation to any
matter other than the matter which has been so
considered and decided.
(3) An order passed under sub-section (1), shall be
deemed to be an order passed under the same provision
of law under which the original order, the mistake in
which was rectified, has been passed."
In view of the legal fiction engrafted in the second
proviso, where an application made by the assessee for
rectification is not rejected by the Assessing Authority within a
period of 60 days from the date of its receipt, the order is
deemed to have been amended so as to rectify the mistake.
8.4 In the present case, no order rejecting the rectification
application has been passed. However, it is the contention of
the State that the order of the Division Bench was made
available to the Assessing Authority only on 23.03.2010 and,
taking note of the same, a rectification order came to be
passed on 08.04.2010. It is, however, not clear as to whether
the said rectification order dated 08.04.2010 was passed
pursuant to the rectification application dated 18.01.2010 or in
exercise of suo motu powers.
8.5 The rectification order dated 08.04.2010 was subjected to
revisional jurisdiction under Section 21(2) of the KST Act. By
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order dated 14.01.2011, the said rectification order was set
aside, with a direction to the Assessing Authority to pass a
fresh order in the light of the judgment of the Division Bench.
In compliance with the said revisional order, a fresh
assessment was made on 16.08.2011. It is also not in dispute
that a refund notice was issued and the refund was granted.
8.6 The petitioner challenged the fresh assessment order as
well as the refund order in appeal before the Joint
Commissioner of Commercial Taxes (Appeals), and the said
appeal came to be dismissed on 17.12.2011. Thereafter, a pay
order was issued on 09.01.2012. The request for grant of
interest on the delayed refund was rejected on 17.07.2012. The
challenge to the said order culminated in dismissal of the
appeal by the Tribunal by order dated 25.01.2018.
8.7 It is not in dispute that the fresh assessment order dated
16.08.2011, the revisional order dated 14.01.2011, and the
appellate order dated 17.12.2011 have not been challenged
and have thus attained finality. The Tribunal, while rejecting
the appeal by order dated 25.01.2018, though accepted the
petitioner's entitlement to interest, reckoned the relevant
period from 23.03.2010, i.e., the date of receipt of the copy of
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the judgment of the Division Bench by the Assessing Authority.
On the same reasoning, the rectification application has also
been rejected, which is impugned in the present appeal.
9. The order of the Tribunal is not sustainable for more than
one reason. The original assessments were completed in the
years 2003, 2004 and 2005 for the assessment years 2002-03,
2003-04 and 2004-05, levying tax at a higher rate. The
petitioner had challenged Entry 17-A in Part 'C' of the Second
Schedule to the KST Act in Writ Petition No.28125/2002,
wherein the said entry was initially quashed. However, the
Division Bench, while setting aside the order of the learned
Single Judge, upheld the constitutional validity of the said
entry.
9.1 There is no dispute with regard to the petitioner's
entitlement to refund in the light of the law declared by the
Division Bench. The controversy is confined only to the delay
and the period of such delay. Though the Tribunal has observed
that there was a delay of a few days, it has erroneously
reckoned the period from 23.03.2010, proceeding on the basis
that the judgment of the Division Bench was brought to the
notice of the Assessing Authority only on that date.
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9.2 The said reasoning is clearly untenable. The petitioner
had filed the rectification application dated 18.01.2010
enclosing a copy of the judgment of the Division Bench dated
15.12.2009, which was received by the Assessing Authority on
22.01.2010. Thus, it is evident that the Assessing Authority had
knowledge of, and was in possession of, the judgment of the
Division Bench as on 22.01.2010.
9.3 The rectification application dated 18.01.2010 was not
rejected within the period of 60 days as stipulated under
Section 25-A of the KST Act. In view of the second proviso to
Section 25-A(1), the said application is deemed to have been
allowed and the assessment orders stood amended by
operation of law upon expiry of 60 days from 22.01.2010, i.e.,
the date of receipt of the application.
9.4 Though it may be open to the Assessing Authority to pass
more than one rectification order, the same must be in
conformity with the statutory provisions. Once the rectification
application dated 18.01.2010 stood allowed by virtue of the
legal fiction, and the deemed rectification had come into force,
the question that arises is whether the Assessing Authority
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could pass another rectification order in derogation thereof. The
answer must be in the negative.
9.5 It is not the case that the authorities were without
remedy. However, so long as the deemed rectification remained
in force, the rectification order dated 08.04.2010 is without
jurisdiction. In this regard, this Court in Wipro Limited,
Infotech Group, Belagola Industrial Area, Metagalli,
Mysore (supra) has held as under:
"8. Admittedly, in the instant case, it is not in dispute
that the Assessing Authority passed an order taking into
account the original return instead of revised return on
31-5-2006, 28-8-2006 and 31-8-2006. The petitioner
had filed the revised returns in Form 4 on 12-4-2006,
19-8-2006 and 30-5-2006. Therefore, in view of second
proviso to Section 25-A of the Act, on expiry of sixty
days, the revised return should have been deemed to
have been accepted. However, after a period of sixty
days, the Adjudicating Authority passed an order on 31-
10-2007, 21-1-2008 and 5-1-2008, which were per se
without jurisdiction. The aforesaid aspect of the matter
was neither considered by First Appellate Authority nor
by the Tribunal. The Tribunal has decided the question of
law erroneously, which arose for its consideration."
9.6 Applying the principles laid down in the aforesaid
decision, and in view of the second proviso to Section 25-A of
the KST Act, upon expiry of 60 days, the rectification
application is deemed to have been allowed and the mistake
stands rectified by operation of law. Any rectification order
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passed after the expiry of the said period is, therefore, per se
without jurisdiction.
9.7 In the light of the aforesaid enunciation of law, we hold
that the rectification order dated 08.04.2010 is without
jurisdiction. Consequently, all subsequent proceedings, namely,
the revisional order dated 14.01.2011, the fresh assessment
order dated 16.08.2011, the refund notice dated 20.08.2011,
and the appellate order dated 17.12.2011, cannot be sustained
in the eye of law.
9.8 When the aforesaid orders are otherwise unsustainable in
law, the mere fact that they have not been challenged would
not operate as an impediment to the petitioner's claim for
interest, the right to which has already accrued by operation of
the second proviso to Section 25A(1) and Section 13-A of the
KST Act. Orders passed without jurisdiction cannot defeat an
accrued statutory right, unless such right is taken away or set
aside in a manner known to law.
9.9 The deemed rectification arising out of the application
dated 18.01.2010 continues to hold the field. The right that has
accrued pursuant to such deemed rectification cannot be
divested by subsequent proceedings which are themselves
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without jurisdiction. Moreover, none of the aforesaid orders
dispute the petitioner's entitlement to refund in the light of the
law declared by the Division Bench. The Tribunal, in its orders
dated 25.01.2018 and 24.06.2019, has proceeded on an
erroneous premise that the judgment of the Division Bench
came to the notice of the Assessing Authority only on
23.03.2010, and that there was no delay if the period was
reckoned from the said date for the purpose of determining the
petitioner's entitlement to interest.
9.10 We find that the aforesaid observation and finding are
contrary to the law and material on record. The rectification
application dated 18.01.2010, enclosing a copy of the judgment
of the Division Bench, bears the acknowledgment seal of the
office of the Deputy Commissioner of Commercial Taxes dated
22.01.2010. Thus, it is evident that the Assessing Authority had
knowledge of the judgment of the Division Bench as on
22.01.2010.
9.11 Be that as it may, by operation of law, the rectification
application dated 18.01.2010 stood allowed upon expiry of the
prescribed period, and the assessment orders stood deemed to
have been rectified. Once such deemed rectification has come
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into force, any subsequent proceedings cannot divest the
petitioner of the accrued right.
9.12 In the light of the above, we are of the considered view
that the petitioner is entitled to interest under Section 13-A of
the KST Act at the rate of 6% per annum for the period of
delay of one year, six months and eighteen days. The said
period is computed on the basis that the rectification
application is to be reckoned from the date of its receipt, i.e.,
22.01.2010. The period of 60 days, as contemplated under the
second proviso to Section 25-A(1) of the KST Act, expired on
22.03.2010, and the further period of 90 days for grant of
refund under Section 13-A KST Act expired on 22.06.2010.
10. In the light of the findings recorded herein above, we
pass the following:
ORDER
(i) Sales Tax Revision Petition No.3/2020 is allowed.
(ii) The order in STA Rectification Nos.05 to 07/2018 dated 24.06.2019 passed by Karnataka Appellate Tribunal at Bangalore is hereby set aside.
(iii) The questions admitted are answered in favour of the petitioner-Assessee and against the Revenue.
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(iv) The petitioner is entitled to interest under Section 13-A of the Karnataka Sales Tax Act, 1957, at the rate of 6% per annum for the period of 1 year, 6 months and 18 days.
(v) No orders as to costs.
Sd/-
(S.G.PANDIT) JUDGE Sd/-
(K. V. ARAVIND) JUDGE VBS