JUDGMENT : A. Pasayat, J. - Doubting correctness of decision rendered by a Division Bench of this Court in M/s. Ajanta Enterprisers v. State of Orissa and Anr. 1994 (II) O.L. Rule 463. this reference has been made to the larger Bench to consider the effect of Section 14C of the Orissa Sales Tax Act, 1947 (in short. the 'Act') relating to date from which higher rate of interest stipulated under the provision is applicable. As dispute revolves round interpretation of Section 14C of the Act, reference to factual aspects is not necessary. 2. Section 14C, the pivotal provision, reads as follows; "14C. Payment of interest on refundable amount Amounts refundable u/s 14, if not refunded within ninety, days from the date of receipt of the application in that behalf from the dealer, shall carry interest at the rate of eighteen percent per annum for the first ninety days and thereafter at the rate of twenty four percent per annum, with effect from the date of expiry of the period specified above. Dispute is the date from which interest is payable by the Revenue, and whether ninety days' time provided for disposal of the application for refund is to be excluded and whether no interest is payable for the said period even if the application for refund is not disposed of within that period. 3. According to learned Counsel for the Petitioner if an application is made for refund and the same is not granted within ninety days from the date of application, amount of refund would carry interest at the rate of eighteen per cent for the first ninety days, i.e., the period provided for disposal of the refund application and thereafter at the rate of twenty four per cent from the date of expiry of ninety days. Interest is payable from the date of application itself, and not after excluding the first ninety days within which period authority was entitled to refund the amount without payment of interest. But if the application is not disposed of within that period, interest becomes payable for that period also. Mr. S.C. Lal, learned Sr. Standing Counsel for the Revenue on the other hand, submitted that the period prescribed for disposal of refund application, i.e., ninety days has to be excluded in both the cases and no interest is chargeable for the said period. 4. Mr. S.C. Lal, learned Sr. Standing Counsel for the Revenue on the other hand, submitted that the period prescribed for disposal of refund application, i.e., ninety days has to be excluded in both the cases and no interest is chargeable for the said period. 4. Provision of Section 14C as substituted by Act 23 of 1983 with effect from 22-8-1983 has been quoted above Dispute can be looked into from the angle as to whether there are three periods involved, i.e., (a) first ninety days during which refund application has to be disposed of, (b) further ninety days period carrying interest at the rate of eighteen per cent; and (c) the period thereafter carrying interest at the rate of twenty four per cent. This according to the Revenue is the time scheme. According to Petitioner, there is no logic in excluding first ninety days. Mr. Lal, learned Counsel for the Revenue to substantiate his argument submitted that in a given case if refund application is disposed of on ninetieth day, no interest is payable. Lesser rate of interest is provided for ninety days thereafter with a view that refund application if not. disposed of within ninety days shall carry some interest. Stringency in the interest rate is introduced in case of failure to pay even after ninety days period during which a lesser rate of interest is prescribed. Reference is also made to Section 13(6) of the Act which deals with rate of interest payable by the Assesses in case of failure to pay tax demanded in terms of notice of demand u/s 13(4) of the Act. Section 13(6) to which reference have been made by learned Counsel for the Revenue reads as follows: 6. Reference is also made to Section 13(6) of the Act which deals with rate of interest payable by the Assesses in case of failure to pay tax demanded in terms of notice of demand u/s 13(4) of the Act. Section 13(6) to which reference have been made by learned Counsel for the Revenue reads as follows: 6. In case a dealer makes default in payment of any amount for the payment of which a notice has been issued under Sub-section (4), by the date of expiry of the period allowed under that Sub-section he shall pay interest on the said amount at the rate of eighteen percent per annum from the said date for the first three months and thereafter at the rate of twenty four per cent per annum: Provided that where any appeal or revision u/s 23 or reference u/s 24 has been preferred, the interest as aforesaid shall be payable from the date specified above on the tax or penalty, if any, ultimately found due from the dealer: Provided further that in case the tax or penalty, if any, is enhanced in such appeal, revision or reference, the interest on the excess amount shall be payable from the date by which the dealer is required to pay such excess amount: Provided also that no interest under this Sub-section shall be charged in respect of any amount which remained unpaid at any time prior to the 1st day of January, 1971. 5. The expression "with effect from the date of expiry of the period specified above" appearing in Section 14C is of significance. Had the expression been not used, provision would have read as follows: 14C. Payment of interest on refundable amount-Amounts refundable u/s 14, if not refunded within ninety days from the date of receipt of the application in that behalf from the dealer, shall carry interest at the rate of eighteen per cent per annum ninety days and thereafter at the rate of percent per annum. 6. According to learned Counsel for Petitioner, the expression is used with reference to the date of expiry of the period specified during which interest is payable at the rate of eighteen per cent and not for the purpose of excluding first ninety days. 6. According to learned Counsel for Petitioner, the expression is used with reference to the date of expiry of the period specified during which interest is payable at the rate of eighteen per cent and not for the purpose of excluding first ninety days. Argument is attractive, but is not sound for the simple reason that provision itself provides that amount refundable carries interest at the rate of eighteen per cent per annum for, the first ninety days and thereafter at the rate of twenty four percent per annum. The word 'thereafter' would become meaningless if interpretation as suggested by Petitioner is accepted. 7. It is well settled principle of law that legislature is not supposed to use unnecessary words. 8. By interpretation or construction is meant", says Salmond, "the proceed by which the courts seek to entertain the meaning of the legislature through the medium of authoritative forms in which it is expressed". (See SALMOND: 'Jurisprudence' 11th Edition, p. 152). It has been said that there is a distinction between the two expressions as observed by the Apex Court in. In re see Customs Act: AIR 1963 S.C. 1760 A. at page 1794. As explained by COOLEY:" Interpretation differs from construction in that former to the art of finding out the true sense of any form of words; that is the sense which their author intended to convey; and of enabling others to derive from them the same idea which the author intended to convey. Construction, on the other hand is the drawing of conclusions, respecting subjects that lie beyond the direct expression of the text from elements known from and given in the text; conclusions which are in the spirit though not within the letter of the law. This distinction however, 'has been largely relegated to the realm of academic discussion. (See CRAWFORD 'Statutory Construction' at page 231) and has been criticized as 'erroneous'.(See SUTHERLAND: 'Statutory Construction', Volume 2, 3rd Edition, Article 1504, at p. 319). Even conceding that there may be some abstract distinction between the two, it cannot be doubted, as was observed by WHITE, J. that "in common usage interpretation and construction are usually understood as having the same significance'. (See United States v. F.W. Keitel 211 U.S. 370). A statute is an edict of the legislature, as observed by the Apex Court in The Vishnu Pratap Sugar Works (P) Ltd. Vs. (See United States v. F.W. Keitel 211 U.S. 370). A statute is an edict of the legislature, as observed by the Apex Court in The Vishnu Pratap Sugar Works (P) Ltd. Vs. The Chief Inspector of Stamps, U.P. and the conventional way of interpreting or construing a statute is to seek the intention of its maker. A statute is to be construed according to the intent of them that make it and the duty of judicature is to act upon the true intention of the legislature the means or sent etiologies. 9. There is a marginal area in which the courts mould or creatively interpret legislation and they are thus finishers, refiners and polishers of legislation which comes to them in a state requiring a varying degrees of further processing. But as observed in London and North Eastern Rly Company v. Berrimen (1946) 1 All E.R. 255, in deciding that 'repair' does not include cleaning and oiling. In all ordinary cases and primarily the language employed is the determining factor of intention. The first and primary rule of construction is that the intention of the legislature must be found in the words used by the legislature itself. The question is not what may be supposed to have been intended but what has been said. If the legislature did intend that which it has not expressed clearly; much more, if the legislature intended something very different; if the legislature intended pretty nearly the opposite of what is said, it is not for judges to invent something which they do not meet within the words of the text (aiding their construction of the text always, of course, by the context). 10. If the words of the statute are in themselves precise and unambiguous, then no more can he necessary than to expound those words in their natural, and ordinary sense. The words themselves do alone in such cases best declare the intent of the of SALES TAX law-giver. When a language is plain and unambiguous and admits of only one meaning no question of construction of a statute arises, for the Act speaks for itself. As stated by the privy council. "We cannot aid the legislature's defective phrasing of an Act, we cannot add or mend and, by construction make up deficiencies which are left there. When a language is plain and unambiguous and admits of only one meaning no question of construction of a statute arises, for the Act speaks for itself. As stated by the privy council. "We cannot aid the legislature's defective phrasing of an Act, we cannot add or mend and, by construction make up deficiencies which are left there. It is contrary to all rules of construction to read words into an Act unless it is absolutely necessary to do so. Similarly it is wrong and dangerous to proceed by substituting some other words for words of the statute." (See Crawford v. Spponar (1846) 6 Moore P.C. 1; and Pinnor v. Everett (1969)3 All E.R. 257 (H.L.) 259). It is not a sound principle of construction to brush aside words in a statute as being inapposite surpluses, if they can have appropriate application in Circumstances conceivably within the contemplation of the statute. It is incumbent on the court to avoid a construction, if reasonably permissible on the language, which would render a part of the statute devoid of any meaning or application. In the interpretation of statutes, the courts always presume that the legislature inserted every part thereof for a purpose and the legislative intention in that every part of the statute should have effect. (See J.K. Cotton Spinning Weaving Mills Company Ltd. v. State of U.P. A.I. Rule 1961 S.C. 1170). The legislature is deemed not to waste its words or to say anything in vain, as observed by the Privy Council in Cuabec Railway Light Heat and Power Company v. Vandry A.I. Rule 1920 P.C. 181. No part of a statute is to be taken as superfluous or redundant. A construction which would leave without effect any part of the language of a statute win normally is rejected. (See Aphali Pharmaceutical Ltd. v. State of Maharashtra (1989) 44 E.L. T. 613). A construction which attributes redundancy to the legislature win not be accepted except for compelling reasons. The rule that a meaning should, if possible be given to every word in the statute implies that, unless there is good reason to the contrary, the words and something which would not be there if the words were left out. (See Hills v. Williams Hill (Park Lane Ltd. (1949) 2 All E. Rule 452 (H.L.) referred to in Sherulal Parakh v. Mahadeodas Maiya A.I. Rule 1959 S.C. 781). (See Hills v. Williams Hill (Park Lane Ltd. (1949) 2 All E. Rule 452 (H.L.) referred to in Sherulal Parakh v. Mahadeodas Maiya A.I. Rule 1959 S.C. 781). We are not concerned with the question whether addition of words is permissible. It is not allowable to read words in a Statute which are not there, but where the alternative lies between either supplying by complication words which appear to have been accidentally omitted and adopting a construction which deprives certain existing words of all meaning, it is permissible to supply the words. Even a departure from the role of literal construction may be legitimate so as to avoid any part of the statute becoming meaningless. (See CRAIGS: Statute Law, 7th Edition,. p. 109: and Siraj-ul-Haq v. Sonni Central Board of Waqf. U.P. A.I. Rule 1959 S.C. 198. But that quest on is really of academic interest in the case at hand. 11. Giving a purposeful and meaningful interpretation to the provision, it is apparent that for the first ninety days during which refund application is to be disposed of, no interest is provided for. Default starts after ninety days period is over and interest is chargeable after exclusion of ninety days period. The expression "with effect from the date of expiry of the period specified above" relates to a ninety days period after the first period of ninety days during which refund application has to be disposed of. As has been rightly submitted by learned Counsel for the Revenue, no interest is payable even if refund application is disposed of on ninetieth days i.e. last date of the period prescribed. Default starts from the next day. Prescription of two different rates is clearly attributable to the legislative intent to impose more stringent rate for continued default. Contrary view expressed in M/s. Ajanta Enterprisers' case (supra) is not correct. 12. Merely because a lesser rate of interest is provided for a period of ninety days, and no interest is payable for the preceding ninety days' period which is prescribed for dealing with refund applications, the concerned Sales Tax Officer should not sit over the matter. Legislature in its wisdom prescribed a period of ninety days for disposal of refund applications. In the normal course, therefore, the refund applications are to be disposed of within ninety days, unless compelling reasons exist for not doing so. Legislature in its wisdom prescribed a period of ninety days for disposal of refund applications. In the normal course, therefore, the refund applications are to be disposed of within ninety days, unless compelling reasons exist for not doing so. The reasons for not disposing of the refund applications within ninety days' period should be clearly recorded. The Commissioner of Sales-tax would do well to issue instructions to all concerned officers to deal with refund applications within the prescribed period so that the State Exchequer is not burdened with interest payable u/s 14C of the Act. Any non-compliance in that regard should be seriously viewed and necessary departmental action shall follow. That shall bring in prompt action on the part of concerned officers. Reference application is accordingly disposed of. S. N. Phukan, C.J. I agree. P. K. Tripathy, J. I agree. Application disposed of.