In the case of Saha Hospitality Ltd. Versus The State of Maharashtra & Ors. by an affidavit in reply filed by |State to Writ Petition ,agaist alleged order for recovery of interest for late filing return/statement in Form 3B, intiamted by email , made statement that procedure for SCN, hearing and order thereafter will be followed thereby dispelling presumption that delayed payment interest is mechnical and summary in nature.Statement is reflected in order dt 14.8.2020. This will also apply to penalties for late filing of Form 3 B and can lead to great relief to tax payers who can seek justice from structured appellate authorities and department will have plethora of proceedings in seveal cases.