Appellate authority can admit delayed C form declarations on sufficient cause and consider extension of time.

C form declarations produced at the appellate stage may be entertained on sufficient cause, and the power to extend time is not confined to the assessing authority. The earlier view that the appellate authority lacked such power was rejected in light of a Full Bench ruling. As the assessee had sought to place the declarations before the first appellate authority, the matter was remitted for that authority to reconsider whether the delayed declarations should be admitted in exercise of its discretion.

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Issues: Whether C form declarations produced at the appellate stage could be entertained on sufficient cause and whether the appellate authority had power to consider extension of time for their filing.

Analysis: A Full Bench decision had already clarified that C form declarations may be entertained out of time by the appellate authority on sufficient cause and that the power to extend time is not confined to the assessing authority. The earlier view that the appellate authority lacked such power was therefore incorrect. As the assessee had sought to place the declarations before the first appellate authority, the matter was considered fit for reconsideration by that authority rather than being finally decided in revision on the material before the Court.

Conclusion: The appellate authority did have power to entertain the C form declarations on sufficient cause, and the matter was sent back for reconsideration in exercise of that discretion.

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