S. R. NAYAK, J. ( 1 ) THE petitioner-dealer has filed this writ petition for mandamus declaring the action of the Commercial Tax officer, Malkajgiri, Ranga Reddy District, the respondent herein, in not paying a sum of Rs. 11,19,165/- towards interest under section 33-F of the APGST Act, 1954 (for short, APGST Act), as illegal and arbitrary. In appreciating this claim of the petitioner, it is necessary to notice the undisputed facts in the first instance. ( 2 ) THE order made by the Sales Tax appellate Tribunal (for short, the Tribunal) for the assessment year 1981-82 and the order made by the Appellate Deputy commissioner for the assessment years 1982-83 to 1986-87, totally for a period of six assessment years, have become final. Under the above two orders of the Tribunal and the Appellate Deputy Commissioner, the petitioner is entitled to seek refund of the tax collected in respect of disputed transactions which are set aside by the learned Tribunal and the Appellate Deputy commissioner. However, as could be seen from the counter-affidavit filed in the writ petition, the petitioner s demand for interest is denied on the ground that the Assessing officer had three years time to give effect to the order made by the learned Tribunal and the Appellate Deputy Commissioner in terms of Section 24-A of the APGST Act and, therefore, the petitioner could claim interest only from the date on which the assessing Officer passed orders consequent upon the orders made by the learned Tribunal and the Appellate Deputy Commissioner, and the petitioner cannot claim interest in terms of Section 33-F read with Section 33-B of the APGST Act from the date on which the period of six months contemplated in section 33-F expired. We do not find any merit in this contention of the Department. Section 24-A does not deal with refund of tax at all. We do not find any merit in this contention of the Department. Section 24-A does not deal with refund of tax at all. It reads -"24-A. Limitation in respect of certain assessments or re-assessments ordered : Notwithstanding anything in sections 14 and 20 where an assessment, re-assessment, rectification in or revision of an assessment is made in respect of an assessee or any person, in pursuance or in consequence of or to give effect to any finding or direction contained in an order under Section 19, Section 20, section 21, Section 22 or Section 23 or in an order of any Court in a proceeding, otherwise than by way of appeal or revision under this Act, such assessment, re-assessment, rectification in or revision of an assessment shall be made within three years from the date of receipt of such order by the assessing or revising authority as the case may be". As could be seen from the above provision, a maximum of three years is granted to the assessing Authority to pass consequential orders or re-assessment order made under sections 19, 20, 21, 22 or 23 of the Act or in an order of any Court otherwise than in Appeal or Revision under the Act. Section 33-F mandates that where a refund is due to the assessee in pursuance of an order referred to in Section 33-B and the assessing authority does not grant the refund within a period of six months from the date of such order, the State Government is charged with liability to pay to the assessee simple interest at 12% per annum on the amount of refund from the date immediately following the expiry of six months. Section 33-B provides that whereas a result of any order passed in appeal or other proceeding under the Act, refund of any amount becomes due to the assessee or the licensee, the assessing authority or the licensing authority shall refund the amount to the assessee or the licensee without his having to make any claim in that behalf, or adjust or apply such amount as provided in Section 33. From the provisions of sections 33-F and 33-B, it is trite, the entitlement of the petitioner to seek refund flows from the order made by the learned tribunal and the Appellate Deputy commissioner in appeals and not from the consequential order made by the assessing authority. From the provisions of sections 33-F and 33-B, it is trite, the entitlement of the petitioner to seek refund flows from the order made by the learned tribunal and the Appellate Deputy commissioner in appeals and not from the consequential order made by the assessing authority. In other words, the refund became due to the assessee from the respective dates on which the learned tribunal and the Appellate Deputy commissioner passed final orders in favour of the petitioner-assessee. If that is so, by virtue of the provisions of Section 33-F and having regard to the admitted position that the assessing authority did not refund the tax before the expiry of the period of six months from the date of the order of the learned Tribunal and that of the Appellate deputy Commissioner, as contemplated under Section 33-F of the Act, the State government is statutorily duty-bound to pay interest with effect from the date on which the period of six months, contemplated under Section 33-F, from the respective date of the order of the learned Tribunal and that of the Appellate Deputy Commissioner, expired. The entitlement of the petitioner for interest guaranteed under Section 33-F has nothing to do with the date on which the assessing authority may pass consequential order in pursuance of the order made by the various Commercial Tax Department authorities and the Tribunal under sections 19, 20, 21, 22 or 23 of the Act. The claim of the petitioner, which in this case flows from the order made by the adjudicatory forums like the Tribunal and the Appellate Deputy Commissioner, cannot be subjected to and/or dependent upon the vagaries and uncertainties that may be adopted and practiced by the assessing authority in passing consequential order. It is not that in the present case the Appellate deputy Commissioner and the learned tribunal had set aside the order under appeals and remanded the proceedings to the assessing authority to re-determine the tax liability de-novo. The orders made by the learned Tribunal as well as the Appellate deputy Commissioner do not grant any discretion to modify or alter the tax liability determined by the Tribunal and the Appellate deputy Commissioner. The orders made by the learned Tribunal as well as the Appellate deputy Commissioner do not grant any discretion to modify or alter the tax liability determined by the Tribunal and the Appellate deputy Commissioner. Therefore, the only thing to be done by the assessing authority in pursuance of the orders made by the learned Tribunal and the Appellate Deputy commissioner is executive in nature, and if that is the position and the refund became due to the petitioner-assessee on the dates on which the final orders were passed by the learned Tribunal and the Appellate deputy Commissioner in the appeals filed by it, it goes without saying that the petitioner is entitled to seek interest with effect from the respective date on which the period of six months from the date of the order made by the learned Tribunal and the Appellate Deputy Commissioner expired. ( 3 ) IN the result and for the foregoing reasons, we allow the writ petition with no order as to cost. A direction shall issue to the respondent to pay to the petitioner- assessee simple interest at the rate of 12% per annum on the refund due and paid to the petitioner from the dates immediately following the expiry of the period of six months from the date of the order of the learned Tribunal for the assessment year 1981-82 and from the date of the order of the Appellate Deputy Commissioner for the assessment years 1982-83 to 1986-87, within a period of one month from the date of receipt of a copy of this order. No costs.