Writ petition dismissed for seeking certified copy after limitation period expired despite proper email service

The AP HC dismissed a writ petition where petitioner sought certified copy of assessment order to file appeal after limitation period expired. Petitioner, a multinational company, claimed F Forms were misplaced and couldn't be submitted timely for turnover exemption. The court held petitioner cannot plead ignorance of law when assessment period for 2015-16 ended on 31.03.2020, yet first action was taken only in June 2022. Service by email was deemed proper under amended Rule 64, and petitioner had duty to update email changes. No grounds existed for court intervention.

---

---

Issues:
1. Exemption sought under Central Sales Tax Act for a specific turnover.
2. Assessment order sent via email not received by petitioner.
3. Refunds denied due to completed assessment in 2019.
4. Request for certified copy of assessment order denied.
5. Disputed F Forms misplaced, affecting appeal filing.
6. Interpretation of Rule 64 of Andhra Pradesh Value Added Tax Rules.
7. Validity of service through email under amended Rule 64.
8. Petitioner's contention on service of assessment order via email.
9. Applicability of Rule 12 of Central Sales Tax Rules on F Forms filing.
10. Direction to Assessing Authority for certified copy of assessment order.
11. Petitioner's awareness of law and assessment completion period.
12. Proper service of order via email and petitioner's duty to update information.
13. Court's decision on intervention in the case.
14. Closure of pending interlocutory applications.

Analysis:
1. The petitioner, a registered dealer under the Central Sales Tax Act, sought exemption for a specific turnover but faced a shortfall in F Forms leading to a demand raised by the Assessing Officer based on an assessment order dated 28.12.2019, sent via email which the petitioner claims to have not received due to the inactive email ID of the recipient officer.

2. The petitioner was unaware of the assessment order and subsequent adjustments resulting in denied refunds, as the officer handling the email ID had left, and the petitioner was not informed of the order. The petitioner's request for a certified copy of the assessment order was denied, hindering the appeal filing process.

3. The petitioner argued that the misplaced F Forms could be rectified during appeals, citing a judgment permitting such actions. However, the inability to file an appeal due to the lack of a certified copy of the order was highlighted, emphasizing the petitioner's limited options and the need for intervention.

4. The petitioner's counsel referred to previous judgments regarding service of notice via email and the subsequent amendment to Rule 64, raising questions about the applicability of the earlier decisions in the current scenario.

5. The court deliberated on the petitioner's duty to update contact information and the validity of email service under the amended rule, ultimately dismissing the writ petition citing the petitioner's delayed actions and lack of grounds for intervention.

6. The court emphasized the petitioner's obligation to stay informed, especially being a large Multi-National Company, and rejected arguments against the email service and the petitioner's delayed response in seeking a certified copy of the assessment order for appeal filing.

---