Later production of E1 and C forms upheld where effective justice required verification for concession claims.

The Tribunal may permit later production of E1 and C declaration forms where their verification is necessary for determining concession or exemption claims, because the controlling consideration for a judicial or quasi-judicial authority is effective justice. Mere earlier non-production, without a convincing explanation, does not by itself require rejection of the documents. Applying that principle, the Tribunal's discretion to accept the forms at a later stage was found proper and free from error, and its order allowing fresh disposal after verification was upheld.

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Issues: Whether the Tribunal was justified in allowing the assessee to produce the E1 and C declaration forms at a later stage for verification and fresh disposal.

Analysis: The Tribunal exercised discretion to permit production of the forms despite earlier non-production. The Court held that the controlling consideration for a judicial or quasi-judicial authority is the requirement of justice and effective justice. Where the documents may affect the availability of concessions or exemptions, mere failure to produce them earlier, without a convincing explanation, does not compel rejection of their subsequent production. The Tribunal was found to have acted within its discretion and without error.

Conclusion: The Tribunal's order permitting later production of the E1 and C forms was upheld, and the petition was dismissed.

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