Electronic filing power upheld, but practical hardship objections to digitally signed Form 15 must be considered.

The statutory scheme for electronic filing and payment authorised the Commissioner to modify prescribed forms and the manner of submission and authentication for implementation of digital filing, so the circular requiring digitally signed online Form 15 for transport of goods was upheld as being within power. The Court, however, recognised a separate claim of practical hardship, including lack of internet access at relevant locations and transport by railway wagons, and directed the Commissioner to consider those representations after hearing affected persons in a representative capacity. The challenge to jurisdiction failed, but administrative reconsideration of the hardship-based objections was ordered in accordance with law.

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Issues: Whether the Commissioner had the authority to issue the circular insisting on digitally signed online Form 15 for transportation of goods and whether the petitioners were entitled to relief on the ground of practical difficulty and discriminatory exemption.

Analysis: The statutory scheme permitted electronic filing and payment, and specifically empowered the Commissioner to make suitable modifications in prescribed forms and in the manner of submission and authentication for implementation of electronic filing. In that setting, the impugned circular could not be invalidated on the ground of want of power or jurisdiction. However, the petitioners had raised a separate grievance regarding practical hardship, including lack of internet access at the relevant locations and transport by railway wagons. The Court found that these representations required administrative consideration by the Commissioner after hearing the affected parties in a representative capacity.

Conclusion: The challenge to the Commissioner's power to issue the circular was rejected, and the petitioners were granted a direction for consideration of their representations in accordance with law.

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