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Issues: Whether the assessing authority was justified in rejecting the C Forms as belated without considering the proviso to Rule 12(7) and the power to condone delay.
Analysis: The assessment order rejected the C Forms only on the ground that they were produced beyond the prescribed time limit, without examining the explanation for delay or the discretion preserved in the proviso to Rule 12(7). The rule, as amended, reduced the time for furnishing C Forms, but left the proviso intact. The retained proviso shows that the power to accept belated forms on sufficient cause continued to survive after amendment. The order also did not discuss whether the delay offered by the assessee was satisfactory or whether the authority had exercised the statutory discretion in accordance with law.
Conclusion: The rejection of the C Forms as merely belated was unsustainable, and the assessment required reconsideration in the light of the proviso to Rule 12(7) and the relevant legal principles.