Physical filing of statutory declarations cannot be rejected where the rules do not require online uploading, and assessments based on that refusal fail.

In the absence of any statutory requirement for electronic filing, statutory declaration forms could not be rejected solely because they were tendered in physical form. The court applied the principle that an assessee's lawful entitlement should not be defeated by a technical insistence not found in the governing rules. On that basis, assessment orders founded on refusal to accept manual declarations could not be sustained, and the assessing authority was directed to accept the physical declarations and complete the assessment.

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Issues: Whether the department could insist upon online uploading of statutory declaration forms and refuse acceptance of manual filing, and whether the assessment orders founded on such insistence could be sustained.

Analysis: The earlier decision relied upon held that, under the Central Sales Tax Act, 1956, the Central Sales Tax (Pondicherry) Rules, 1967 and the Central Sales Tax (Registration & Turnover) Rules, there was no provision requiring declaration forms to be submitted electronically in the manner demanded by the department. The demand for online uploading was therefore inconsistent with the governing rules. The principle applied was that an assessee's lawful entitlement should not be denied on technical objections where the statute did not require electronic filing. In the present matters, the impugned orders were passed on the same footing and were directly covered by that reasoning.

Conclusion: The insistence on online uploading of declaration forms was unjustified, the impugned orders were set aside, and the Assessing Authority was directed to accept the statutory declarations in physical form and complete the assessment.

Ratio Decidendi: In the absence of a statutory requirement for electronic filing, declaration forms cannot be rejected merely because they are tendered in physical form, and assessments based on such rejection cannot stand.

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