(1.) Heard Sri M. Manglik, learned counsel for the revisionist and Sri B.K. Pandey, learned Standing Counsel for the respondent/Commissioner, Trade Tax/Revenue.
(2.) It has been contended on behalf of the applicant/revisionist that the present controversy was beyond the purview of Section 22 of the Act and there cannot be any liability of interest also.
(3.) Under identical circumstances, a division Bench of this Court in the case of Ganesh International v. Assistant Commissioner since reported in [2001] 124 STC 600 ; 2000 UPTC 1097 has observed as below :