JUDGMENT :- Ramachandran Nair, J. 1. The question raised in the Writ Appeal is whether in the course of recovery of motor vehicle tax along with additional tax for default payable under Section 12 of the Kerala Motor Vehicles Taxation Act (hereinafter called "the MVT Act") default interest under Section 6 of the Revenue Recovery Act (herinafter called "the RR Act") also could be recovered by the Revenue Recovery authorities. Learned Single Judge upheld demand of interest under Section 6 of the RR Act against which the Writ Appeal is filed. We have heard counsel appearing for the appellant and also Government Pleader for the respondents. 2. The arrears of tax involved in this case is due for a stage carriage operated by the appellant. Vehicle fell in arrears of tax for the year 1999. The R.T.O. recommended recovery of motor vehicle tax and additional tax due under Section 12 of the MVT Act for recovery under the RR Act. The vehicle involved was seized and sold by the Revenue Recovery authorities for Rs.40,500/-in the year 2001 and after adjusting collection charges the balance amount was credited towards arrears of tax. When the second vehicle was attached, the appellant approached this court and in terms of the interim orders issued by this court, appellant on 26.6.2007 paid arrears of motor vehicle tax and also collection charges demanded by the Revenue Recovery authorities. However, in addition to recoveries so made, the Tahsildar has served a demand notice for recovery of a further sum of Rs.25,384/-towards interest due under Section 6 of the RR Act, against which the appellant approached this court with the writ petition which was dismissed by the learned Single Judge, the correctness of which is the matter to be decided by us in this Appeal. 3. The contention raised by the appellant is that additional tax payable under Section 12 of the MVT Act is actually default interest the maximum of which is 50% of the tax. However, Government Pleader contended that additional tax payable under Section 12 is an independent levy by itself for default committed by vehicle owners liable to pay motor vehicle tax and though it is for default, it cannot be treated as interest in the first place. However, Government Pleader contended that additional tax payable under Section 12 is an independent levy by itself for default committed by vehicle owners liable to pay motor vehicle tax and though it is for default, it cannot be treated as interest in the first place. The second contention of the Government Pleader is that when tax and additional tax are recommended for recovery by R.T.O. which is recoverable as arrears of land revenue due as per Section 13 of the MVT Act, interest payable under Section 6 of the RR Act is automatic and the defaulter has no escape from it. Even though in principle the contention of the Government Pleader is tenable, we notice a distinction in regard to interest payable under Section 6 of the RR Act in the course of recovery of arrears of motor vehicle tax because of the operation of Section 12 of the MVT Act which is default-tax geared to the period of delay in payment of tax. Section 12(1) and (2) and Section 13 of the MVT Act are extracted hereunder for easy reference: "S.12. Additional tax payable when tax not paid: - (1) When any registered owner or any person who has possession or control of any motor vehicle used or kept for use in the State has not paid the tax within the prescribed period, he shall pay, in addition to the tax, an additional tax of the such amount as may be specified by the Government by Notification in the Gazette, not exceeding the amount of the tax due. (2) The additional tax under sub-section (1) shall be paid along with the arrears of tax............." "S.13. Amounts recoverable as arrear of land revenue: - (1) Any amount due under this Act and Rules made thereunder shall be recoverable in the same manner as an arrear of public revenue due on land. ...................." Notification SRO 353/99 provides for payment of additional tax under Section 12 as follows: TABLE II Additional tax in respect of Motor Vehicles for which tax is realized quarterly— It is clear from Table 2 of the notification above referred that default-tax payable is directly proportionate to the period of delay in payment or recovery. ...................." Notification SRO 353/99 provides for payment of additional tax under Section 12 as follows: TABLE II Additional tax in respect of Motor Vehicles for which tax is realized quarterly— It is clear from Table 2 of the notification above referred that default-tax payable is directly proportionate to the period of delay in payment or recovery. In fact, while the minimum additional tax payable is 10% which applies to cases where arrears are paid within one month after the prescribed period, the maximum is 50% of the tax which applies to payment or recovery beyond six months from the expiry of the prescribed period for payment. It may so happen that immediately on default, the R.T.O. may refer a case of arrears of motor vehicle tax for recovery under the RR Act and prompt recovery can be made by the R.R. authorities at any time after receipt of requisition from the R.T.O. When arrears of motor vehicle tax is recovered under the RR Act treating it as arrear of public revenue in terms of Section 13 of the MVT Act, normally the Revenue recovery authorities charge interest under Section 6 of the RR Act which is 12% per annum for the period of default until recovery from the date of requisition. However, additional tax which is also liability for default in payment is payable even after initiation of R.R. proceedings in terms of Table 2 prescribed by the Government under notification issued under Section 12 of the MVT Act. Therefore, the question to be considered is whether for the same period of default additional tax under Section 12 of the MVT Act and interest under Section 6 of the RR Act are payable by the defaulter. There is nothing to indicate in the MVT Act that Section 12 ceases to be operational as and when R.R. proceedings are initiated for recovery under Section 13 of the Act. Therefore, additional tax will run even after initiation of R.R. proceedings by the R.T.O. So much so, if recovery happens to be made by the Revenue Recovery authority within or soon after expiry of six months from the expiry of the period for payment of motor vehicle tax, then the Recovery Authority should recover only additional tax payable on the arrears of tax under Section 12 of the MVT Act read with notification above stated. So far as interest liability under the RR Act is concerned, Section 6 of the RR Act provides as under: "S.6. Interest on arrears of public revenue due on Land:-Arrears of public revenue due on land shall bear interest at the rate of 12 per cent per annum or at such other rate as may be notified by the Government from time to time in the Gazette." We are of the view that in substance the additional tax payable under Section 12 of the MVT Act is like default interest because the MVT Act does not provide for any interest for delayed payment of tax except the default tax payable under the said provision. Moreover, besides Motor Vehicle authorities Police are also entitled to recover arrears of motor vehicle tax through coercive methods like detention of vehicle and release after clearing the arrears. Since the maximum additional tax payable under Section 12 of the MVT Act read with notification above stated is for default beyond six months and no separate interest is provided under the said Act, we do not think the mere initiation of Revenue Recovery proceedings immediately after default entitles the Revenue Recovery authorities to recover interest under Section 6 of the RR Act in addition to additional tax payable under Section 12 of the MVT Act for the same period of default. So much so, no interest under Section 6 of the RR Act is payable by defaulter for any period for which additional tax is payable for delay in payment of motor vehicle tax under Section 12 of the MVT Act. In other words, even when recovery of motor vehicle tax is made by Revenue Recovery authorities, they should also recover along with arrears of tax, additional tax payable under Section 12 up to first six months of default and for period thereafter interest under Section 6 of the RR Act is recoverable both on arrears of tax and additional tax. 4. In this case Revenue Recovery is initiated for recovery of arrears of tax as well as additional tax for the maximum period of default for which additional tax is payable under Section 12 of the MVT Act and so much so, interest was rightly charged on appellant. We, therefore, do not find any merit in the challenge against the demand of interest under Section 6 of the RR Act. We, therefore, do not find any merit in the challenge against the demand of interest under Section 6 of the RR Act. Accordingly Writ Appeal is disposed of directing the R.T.O. to verify the factual position in regard to period of default and the recoveries and adjustments so far made and limit the interest liability due under Section 6 of the RR Act only for the period of delay in payment/recovery after the expiry of first six months of the period of default for which only additional tax could be recovered under Section 12 of the MVT Act. 5. So far as the collection charge payable under Section 5 of the Revenue Recovery Rules is concerned, it should be limited to the amount recovered by sale of the vehicle and no collection charges should be demanded from the appellant for the voluntary payment made based on interim orders issued by this court. The Revenue Recovery Authority is directed to recompute liability for interest payable as on the date of full payment of arrears of tax made by the appellant. Appellant is granted time till 30.9.2012 to clear the balance arrears of interest due after setting off collection charges recovered on voluntary payment against interest liability on which no further interest should be charged, if appellant makes payment as above.