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Issues: Whether the appellate authority could accept C declaration forms produced for the first time before it and, if scrutiny of their genuineness was necessary, whether the matter should be remitted to the assessing authority instead of finally acting on the forms.
Analysis: The dealer had shown sufficient reason for not producing the declaration forms before the assessing authority. On that basis, the appellate authority was justified in receiving them. However, where the genuineness of the forms required verification, the proper course was not to straightaway grant relief on their basis but to remit the matter to the assessing authority for scrutiny and fresh consideration in accordance with law.
Conclusion: The acceptance of the forms at the appellate stage was upheld in principle, but the appellate authority erred in granting relief without remand for verification; the Commissioner's order was therefore interfered with only to the extent indicated.
Final Conclusion: The dispute was restored to the assessing authority for verification of the declaration forms and a fresh assessment, while the appeal succeeded against the Commissioner's complete disallowance of the appellate order.
Ratio Decidendi: Where declaration forms are not produced at the assessment stage for sufficient cause, an appellate authority may receive them, but if their genuineness requires scrutiny the matter should be remitted for verification rather than finally determined on the spot.