Post-assessment E-I forms may still support CST exemption if sufficient cause for delay is shown.

Rule 12(7) of the Central Sales Tax (Registration and Turnover) Rules, 1957 permits the prescribed authority to accept statutory declarations or certificates beyond the assessment stage if sufficient cause is shown. That principle applies to E-I forms as well as C forms. Where E-I forms are produced after finalisation of assessment but before the proceedings are finally concluded, they may still be taken into account for exemption under section 6(2) of the Central Sales Tax Act, provided sufficient cause for the delay is proved. The Andhra Pradesh HC applied that approach and treated the post-assessment forms as admissible in favour of the assessee.

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Issues: Whether E-I forms produced after finalisation of the assessment before the first assessing authority could still be taken into account for exemption under section 6(2) of the Central Sales Tax Act when sufficient cause under rule 12(7) of the Central Sales Tax (Registration and Turnover) Rules, 1957 was shown.

Analysis: Rule 12(7) permits the prescribed authority to accept the relevant declaration or certificate beyond the time of assessment if sufficient cause is established. The provision applies not only to C forms but also to E-I forms. Following the earlier view that the appellate authority can receive such forms during pendency of proceedings, the same principle applies where the forms are filed subsequent to the assessment but before the matter is finally concluded, subject to proof of sufficient cause.

Conclusion: E-I forms filed after the assessment could be considered upon sufficient cause being shown, and the point was decided in favour of the assessee.

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