Belated statutory forms may be admitted on sufficient cause when bona fide efforts failed to secure them before assessment.

Statutory declarations in Form C and certificates in Form E-1, though not produced during assessment, may be admitted at the first appellate stage where the assessee shows sufficient cause for the delay and bona fide efforts to obtain them before assessment was completed. Correspondence on record supported the explanation that the forms became available only after assessment. On those facts, the appellate authority ought to have received and acted upon the documents, and the belated forms were entitled to appellate consideration.

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Issues: Whether the assessee had sufficient cause for producing the declarations in form C and the certificates in form E-1 for the first time before the first appellate authority, and whether those documents ought to have been accepted and acted upon.

Analysis: The assessee could not secure the requisite forms before completion of assessment despite efforts made for that purpose. The record showed correspondence supporting the explanation that the documents became available only after the assessments were completed. Where sufficient cause is shown, the first appellate authority has jurisdiction to receive such documents, and the appellate stage is not to be treated as a matter of right for choosing an alternative time to furnish statutory forms. On the facts, the explanation for the delayed production was adequate and should have been accepted by the appellate authorities.

Conclusion: The issue was answered in favour of the assessee. The declarations in form C and the certificates in form E-1 ought to have been admitted and given effect to by the first appellate authority.

Final Conclusion: The references were disposed of by holding that the assessee was entitled, on the facts, to have the belated forms accepted for appellate consideration.

Ratio Decidendi: Statutory declarations or certificates not produced at assessment may be accepted at the appellate stage where the assessee establishes sufficient cause for the delay and the documents are shown to have been unobtainable despite bona fide efforts before assessment was completed.

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