FERTILIZER CORPORATION OF INDIA LTD. vs STATE OF BIHAR

The Supreme Court held that the assessee is entitled to a rebate under Section 15 of the Bihar Sales Tax Act, 1959, despite filing quarterly returns late, as the tax was paid before the due date. The Court interpreted the procedural content of Section 15 liberally, emphasizing that the principal object of the provision—to confer a benefit for prompt tax payment—was not frustrated. The absence of a penalty or adverse assessment by the authorities further supported the assessee's claim for rebate.