Judgment B. Prasad, J.-Heard. 2. All these revision petitions carry common questions of law. Therefore, they are being decided by a common order. 3. The question involved in these revision petitions is whether the interest which is payable under Section 23(2) of the Rajasthan Sales Tax Act, 1994, (for short the Act), would also carry interest on it, if the payment is delayed. The learned Counsel for the petitioner urged that under Section 23 the tax which is deducted by the dealer is liable to be refunded if it is in excess of the amount due under the Act against the assessee. As and when such excess amount is ordered to be refunded, it is to carry alongwith it an interest as defined under Section 23(3) of the Act. 4. The case of the learned Counsel for the petitioners is that the refund which was required to be made in their case, was not made forthwith and it was after strenuous efforts on the part of the assessee that the Revenue decided to return the amount of excess tax paid by them. This is not disputed that whatever amount was refunded had carried interest as is levied in terms of Sub-section (2) of Section 23. The case of the learned Counsel for the petitioner is that since the refund has been made late, the interest which has been paid to him under Section 23 (2) should also carry interest for the delayed period. In support of his claim he has relied on a decision of the Supreme Court in the matter of Commissioner of Income Tax vs. Narendra Doshi, 2002 (254) ITR 606. 5. The learned Counsel for the Revenue urged that the argument of the learned Counsel for the petitioner is per se misleading. The case relied on by the learned Counsel is not a case where the Honble Supreme Court had laid down any law. It is only based on judicial propriety because in the same kind of circumstances, the revenue had not chosen to challenge the orders of similarly situated persons and in that background, the Honble Supreme Court ordered the payment of interest on interest. The learned Counsel has relied on the Haryana Financial Corporation and Anr. It is only based on judicial propriety because in the same kind of circumstances, the revenue had not chosen to challenge the orders of similarly situated persons and in that background, the Honble Supreme Court ordered the payment of interest on interest. The learned Counsel has relied on the Haryana Financial Corporation and Anr. vs. Jagdamba Oil Mills and Another, 2002 (3) SCC 496 , and has submitted that the law, as decided by the Supreme Court has to be read in the light of the Judgment delivered by the Honble Supreme Court in that case. The Supreme Court in Haryana Financial Corporations case (Supra) held as under: “Court should not place reliance on decisions without discussing as to how the factual situation fits in with the fact situated of the decision on which reliance is placed. Observations of Courts are not to be read as Euclids theorems nor as provisions of the statute. These observations must be read in the context in which they appear. Judgment s of Courts are not to be construed as statutes. To interpret words, phrases and provisions of a statute, it may become necessary for Judges to embark upon lengthy discussions but the discussion is meant to explain and not to define. Judges interpret statutes, they do not interpret Judgment s. They interpret words of statutes, their words are not to be interpreted as statutes." 6. The learned Counsel has further relied on a decision of the Supreme Court in India Carbon Ltd. vs. State of Assam, 1997 (106) STC 460, wherein the Honble Supreme Court has held as under:-“This proposition may be derived from the above : interest can be levied and charged on delayed payment of tax only if the statute that levies and charges the tax makes a substantive provisions in this behalf .” 7. Learned Counsel for the Revenue has urged that Section 23(1) speaks about the refund of excess tax paid and interest is to be paid while the refund is made of the excess tax paid. Section 23(1) reads as under: “23. Learned Counsel for the Revenue has urged that Section 23(1) speaks about the refund of excess tax paid and interest is to be paid while the refund is made of the excess tax paid. Section 23(1) reads as under: “23. Refunds.-(1) The assessing authority shall, in the prescribed manner refund to a dealer any amount of tax paid by such dealer in excess of the amount due from him under this Act, either by cash payment or by deduction of such excess from the amount of tax due in respect of any other period.” (2) An amount refundable to a dealer under this Act shall carry interest at the rate of 4 [15] per cent per annum with effect from the date of deposit of the amount to be refunded.” 8. Interest on interest has not been provided under the section unless there is a charge in section such amount cannot be paid. 9. I have considered the rival submissions and have given my thoughtful consideration to the facts obtaining on record. 10. The law relied on by the Counsel for the petitioner in Narendra Doshiss case (Supra) cannot be considered to be a proposition of law decided by the Supreme Court. It was only in a particular State of circumstances that it has ordered the payment of interest on interest but the same cannot be considered to be a law laid down in terms of the Judgment of Honble Supreme Court in the matter of Haryana Financial Corporations case (Supra). Section 23(1) only speaks of the refund of excess amount. Interest is only chargeable on that excess payment which is liable to be refunded. There is no chargeability of interest on the interest liable to be paid. 11. In that view of the matter no law authorises payment of interest on interest as far as refund under Section 23 of the Act is concerned. That being the position the Judgment s of the Tax Board and the authorities below suffer from no illegality. There is no force in these revision petitions. The same are, therefore, dismissed.