Belated Form-C declarations may be accepted on sufficient cause, preserving concessional sales tax treatment at appeal stage.

Form-C declarations may be produced beyond the prescribed time where sufficient cause is shown, because the appellate stage is treated as a continuation of assessment proceedings. On that basis, the appellate authority can accept belated declarations under the Central Sales Tax framework when the assessee shows diligent efforts to obtain the forms and explains the delay. Where the delay is satisfactorily accounted for, the concessional tax treatment remains available on the belatedly filed declarations.

---

---

Issues: Whether Form-C declarations produced belatedly could be accepted at the appellate stage on showing sufficient cause and whether the concessional rate of tax could be granted on that basis.

Analysis: Section 8(4) of the Central Sales Tax Act, 1956 and Rule 12(7) of the Central Sales Tax (Registration and Turnover) Rules, 1957 permit production of declaration forms within the prescribed time, and further time may be allowed for sufficient cause. The Court held that an appeal is a continuation of the assessment proceedings, and therefore the appellate authority has power to receive Form-C declarations where genuine sufficient cause is shown. On the facts, the assessee had taken diligent steps to procure the forms and produced them belatedly after issuing notice to the purchaser, so the delay was explained.

Conclusion: The belated Form-C declarations were liable to be accepted, and the assessee was entitled to the concessional tax treatment.

---