CST declaration forms cannot be rejected for lack of online upload when physical originals are validly produced.

The statutory scheme governing CST declaration forms permits filing within the prescribed time and allows further time for sufficient cause, and Rule 14(4) also recognises submission before final assessment. On that basis, an assessing authority cannot impose an additional electronic-upload requirement where the governing provisions do not require it. Physical production of original declaration forms cannot be rejected on a technical ground when the statute allows acceptance, particularly where delay is attributable in part to the department's own online system requirement. The operative result is that online uploading cannot be treated as a precondition for CST concession or exemption in the absence of supporting law.

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Issues: Whether the assessing authority could insist on online uploading of statutory declaration forms as a condition for granting CST concession or exemption, and reject physical forms already produced by the assessee.

Analysis: The statutory scheme under Sections 6A, 8(4) and 13 of the Central Sales Tax Act, 1956 and Rule 12(7) of the Central Sales Tax (Registration and Turnover) Rules, 1957 requires furnishing of declaration forms within the prescribed time, with power to grant further time for sufficient cause. Rule 14(4) of the Central Sales Tax (Pondicherry) Rules, 1967 also permits submission of declaration forms before final assessment. None of these provisions required electronic uploading of the forms. The insistence on online uploading, in the absence of a supporting rule, was an additional condition imposed by the Department and could not displace the assessee's physical production of the original declarations. The delay in furnishing the forms was, at least in part, attributable to the Department's own online system requirement, and the forms could not be rejected on a technical ground when the statute permitted their acceptance.

Conclusion: The insistence on online uploading was unlawful, and the assessee was entitled to have the physical declaration forms accepted for assessment.

Ratio Decidendi: Where the statute permits furnishing of declaration forms in the prescribed manner and also enables extension of time for sufficient cause, the assessing authority cannot add an electronic-upload requirement not found in the governing law and reject otherwise valid physical declarations.

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