Belated declaration forms under CST rules cannot reopen concluded assessments after extraordinary delay; writ petitions failed.

Rule 12(7) of the Central Sales Tax (Registration and Turnover) Rules, 1957 permits declaration forms to be furnished after the prescribed period on sufficient cause, but only within a reasonable time and subject to practical verification. The Karnataka HC noted that declaration forms may, in appropriate cases, be accepted later, yet that discretion cannot be used to extend filing by decades or to reopen completed assessments after statutory time limits have expired. Because no forms had been filed at all and the assessments were long concluded, the belated request to file forms and seek reassessment was not permissible. The writ petitions were therefore rejected and the assessment orders left undisturbed.

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Issues: Whether declaration forms under Rule 12(7) could be permitted to be furnished at a belated stage, after decades, so as to seek re-assessment of the completed tax assessments and enable the assessee to avail a subsequent settlement scheme.

Analysis: Rule 12(7) of the Central Sales Tax (Registration and Turnover) Rules, 1957 permits declaration forms to be furnished beyond the prescribed period if sufficient cause is shown, but the discretion is conditioned by reasonableness. The Court held that although declaration forms need not invariably accompany the returns and may, in appropriate cases, be accepted later, the power cannot be invoked to extend the filing period by decades. The relevant assessment years were long concluded, statutory time limits for assessment-related proceedings had expired, and the genuineness of such forms could no longer be meaningfully verified. The Court distinguished the earlier authority relied on by the petitioner on the footing that, in the present case, no declaration forms had been filed at all and only a belated permission to file them was sought.

Conclusion: The request to remand the matter for filing declaration forms after such inordinate delay was not permissible, and the challenge to the assessment orders was rejected.

Final Conclusion: The writ petitions failed because belated acceptance of declaration forms could not be ordered on the facts, and the completed assessments were left undisturbed.

Ratio Decidendi: A statutory discretion to accept declaration forms on sufficient cause must be exercised within a reasonable time and cannot be used to reopen concluded assessments after extraordinary delay.

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