Late filing of genuine statutory declarations cannot justify rejection; assessment must be reconsidered after taking the forms on record.

Late production of genuine and relevant statutory declarations, such as forms C and H, cannot be rejected solely because they were filed for the first time in revision when their authenticity and nexus with the transactions are not disputed. On that basis, the assessment could not stand as framed, and the revisional order also required interference. The matter had to be sent back for a fresh assessment after the declarations were taken on record, so that the assessee could raise all available contentions and the assessment could be reconsidered on the merits of those forms.

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Issues: Whether forms C and H filed for the first time in revision could be taken on record and, if so, whether the assessment and revisional orders required interference with a remand for fresh assessment.

Analysis: The forms were not rejected on any finding that they were forged, irrelevant, or unrelated to the transactions in question. The only reason for refusal was delay in filing. Where the authenticity and relevance of the declarations are not in doubt, mere late production does not justify exclusion of the documents. Once the declarations are admitted, the assessment has to be reconsidered on their basis, and the matter must go back for fresh adjudication so that the assessee may raise all available contentions.

Conclusion: The forms were required to be taken on record, and the assessment and revisional orders were liable to be set aside with a remand for de novo assessment.

Final Conclusion: The writ petition succeeded, the impugned orders were annulled, and the matter was remitted for fresh assessment after considering the declarations filed by the assessee.

Ratio Decidendi: Late filing of genuine and relevant statutory declarations cannot be a sole ground for their rejection when their authenticity and nexus with the transactions are not disputed; once admitted, the assessment must be redone on that basis.

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