ORDER : A.K. Jayasankaran Nambiar, J. As all these O.T. Revisions deal with a common issue, they are taken up together for consideration and disposed by this common order. 2. The State of Kerala, who is the petitioner in all these O.T. Revisions, has raised the following substantial questions of law: (a) Whether on the facts and the circumstances of the case the Appellate Tribunal has erred in law in holding that even though the respondent has collected tax at the rate in excess of the rate permitted, the said collection cannot said to be excess collection, since the tax liability of the respondent is higher than the tax so collected? (b) Whether in the facts and circumstances of the case the Appellate Tribunal ought to have held that in the case of collection of tax in excess of rate permitted the respondent has to pay the said excess collected tax with interest to the Government, even if the tax liability of the respondent is higher than the tax so collected? 3. The respondents/assessees in these Revisions had opted to pay tax at the compounded rate provided under Section 8(f) of the Kerala Value Added Tax Act [hereinafter referred to as the “KVAT Act”]. The assessment years for which they had preferred the option were 2011-12 to 2014-15 in the case of the respondents in O.T. Revision Nos.124, 140, 147 and 156 of 2020 and assessment year 2014-15 in the case of the respondent/assessee in O.T. Revision No.83 of 2018. It would appear that while the respondents/assessees paid tax in accordance with the formula prescribed under Section 8(f), they collected tax at rates in excess of what was prescribed under the proviso/table under Section 8(f). The details of the tax collected by the respondents/assessees in O.T. Revision Nos.124, 140, 147 and 156 of 2020 are given in the table below: Year Turnover reported Tax eligible to collect Compounded tax fixed Tax collected 2011 - 12 35,96,898 44,961 (@1.25%) 2,68,068 1,43,800 2012 - 13 42,48,023 53,100 (@1.25%) 3,05,232 1,71,283 2013 - 14 36,44,771 45,560 (@1.25%) 3,32,703 1,45,749 2014 - 15 25,47,321 26,237 (@1.03%) 3,42,684 1,02,252 4. Similarly, the details of the tax collected by the respondent/assessee in O.T. Revision No.83 of 2018 is as follows: Month Tax collected Tax to be collected @ 1.15% (Rs.) Excess collected (Rs.) April 24382480.00 22355410.00 2027070.00 May 27124257.00 24931242.00 2193015.00 June 19778517.00 18196339.00 1582178.00 July 15366028.00 14635020.00 731008.00 Total 86651282.00 80118011 6533271.00 It will be apparent from the above tables that the respondents/assessees had collected tax at rates higher than what was prescribed under Section 8(f). The Department therefore initiated action against them for recovery of the excess amounts collected by them by relying on the statutory provisions which made it clear that a dealer who opts for payment of tax under Section 8(f) may collect tax at the rate as shown in the table/proviso but where the tax so collected during the year is in excess of the tax payable for the year under the clause, the tax collected in excess shall be paid over to the Government in addition to the tax payable under the said clause. 5. Before the Appellate Tribunal, the case of the respondents/assessees was essentially that notwithstanding the fact that they had collected tax from their purchasers at rates higher than what was prescribed under the Section, inasmuch as the total tax collected by them from their purchasers was less than the tax that was payable by them under the said Section, there was no requirement for payment of the excess tax collected to the Government. The said contention appears to have appealed to the Appellate Tribunal which found in favour of the respondents/assessees on the said aspect and held that inasmuch as the tax collected by the assessees never exceeded the compounded tax payable by them, there was no obligation on them to pay the excess amounts collected to the Government. It is impugning the said finding by the Appellate Tribunal in the orders impugned in these O.T. Revisions, that the State has approached this Court. 6. We have heard Sri.V.K.Shamsudheen, the learned Government Pleader for the petitioner and Sri.K.M.Firoz, the learned counsel for the respondents/assessees in these Revision Petitions. 7. On a consideration of the rival submissions, we find ourselves unable to accept the interpretation of the Appellate Tribunal of the provisions of Section 8(f). 6. We have heard Sri.V.K.Shamsudheen, the learned Government Pleader for the petitioner and Sri.K.M.Firoz, the learned counsel for the respondents/assessees in these Revision Petitions. 7. On a consideration of the rival submissions, we find ourselves unable to accept the interpretation of the Appellate Tribunal of the provisions of Section 8(f). The proviso to Section 8(f)/Section 8(f)(iii) deals with a situation where a dealer in bullion or ornaments or wares or articles of gold, silver or platinum group metals including diamond, who has chosen to pay tax at the compounded rate under Section 8 of the KVAT Act, in lieu of the normal rate under Section 6 of the KVAT Act, is permitted to collect tax from the person to whom he has sold goods at the prescribed rate. The second limb of the said provision clarifies that if the tax so collected during the year is in excess of the tax payable for the year then the tax collected in excess shall be paid over to the Government in addition to the tax payable under Section 8(f). Here, the words “tax so collected” appearing in the second limb assumes importance. In our view, it must be seen as a reference to the tax that is permitted to be collected under the first limb of the provision namely, tax at the rate prescribed therein. Thus, if a dealer collects tax at a rate different from the rate prescribed in the first limb of the proviso/Section 8(f)(iii), then it would not answer to the description of “tax so collected” for attracting the second limb of the provision. It is apparent therefore that the finding of the Appellate Tribunal, in the orders impugned in these O.T. Revisions, are contrary to the express provisions of Section 8(f)(iii)/proviso to Section 8(f). 8. We are also not impressed with the argument of the learned counsel for the respondents/dealers that a registered dealer, as opposed to a dealer simplicitor, who opts to pay tax under Section 8(f) of the KVAT Act can nevertheless collect tax as per the rates indicated in Section 6 by invoking the provisions of Sections 30(1) and (2) of the KVAT Act. Section 30(1) and (2) of the KVAT Act read as under: “30. Section 30(1) and (2) of the KVAT Act read as under: “30. Collection of tax by dealers:- (1) A registered dealer may, subject to the provisions of sub-sections (2) and (3), collect tax at the rates specified under section 6, on the sale of any goods, from the person to whom he sells the goods and pay it over to Government in such manner as may be prescribed. (2) Dealers registered under this Act, except those dealers paying presumptive tax under sub section (5) of section 6 and those paying tax under clause (a) of section 8 by those undertaking works of Government of Kerala, Kerala Water Authority and Local Authorities, and under clause (b), clause (c) (ii) and clause (d) of section 8, alone shall be eligible to collect any sum by way of, or purporting to be by way of tax under this Act: Provided that the dealers who are paying tax under subsection (5) of section 6 are entitled to recover from the buyers the amount of tax paid by him on the purchase value of such goods at the time of purchase.” 9. Section 30(1) clearly envisages a situation where a registered dealer is permitted to collect tax at the rates specified in Section 6. Thus, the provision, even if it applies in respect of registered dealers who pay tax under Section 8, cannot apply to cases where the dealer is permitted to collect tax only at the rates specified under Section 8. That apart, even if such a dealer collects tax at the rate specified under Section 6, he is obliged in terms of Section 30(1) of the KVAT Act to pay it over to the Government since there is no provision similar to the proviso to Section 8(f)/Section 8(f)(iii), in Section 30(1) of the KVAT Act. Thus, in any view of the matter, we find that the order of the Appellate Tribunal impugned in these Revisions cannot be legally sustained. We therefore allow these O.T. Revisions, by setting aside the impugned orders of the Appellate Tribunal and answering the questions of law in favour of the Revenue and against the assessees. The O.T. Revisions are allowed as above.