Section 72. Interest on duty, surcharge or penalty

(1) Where any amount of duty or surcharge is recoverable from a person as a result of any, order passed in any proceeding under this Act (including determination, appeal, revision, rectification or otherwise), he shall be liable to pay interest at the rate of twelve percent compounded per annum on the amount of duty or surcharge from the date of execution of such instrument until the date of payment of such amount. (2) Where any amount of penalty is recoverable from a person as a result of any order passed under this Act, he shall be liable to pay interest at the rate of twelve percent compounded per annum on the amount of such penalty from the date of such order until the date of payment of such amount.