Belated C and F Forms and clerical assessment errors may still be considered on sufficient cause and proper objection.

Rule 12(7) of the CST (R&T) Rules allows the assessing authority to grant further time for filing C Forms and F Forms where sufficient cause explains the delay, so belated statutory declarations may still be considered after assessment if the dealer satisfies that standard. Apparent arithmetical or clerical mistakes in an assessment order must also be examined and corrected by the assessing authority when properly pointed out by the dealer, rather than being left to a separate appeal remedy alone. The document thus states that late statutory forms are not automatically excluded after assessment and that obvious computational or clerical errors remain open to correction on objection.

---

---

Issues: (i) whether the dealer could be permitted to furnish C Forms and F Forms after completion of assessment on showing sufficient cause for the delay; (ii) whether the assessment order could be corrected for arithmetical or clerical mistakes pointed out by the dealer.

Issue (i): whether the dealer could be permitted to furnish C Forms and F Forms after completion of assessment on showing sufficient cause for the delay.

Analysis: Rule 12(7) of the CST (R&T) Rules prescribes the time for furnishing declarations in Form C and Form F and also empowers the authority to allow further time where sufficient cause prevented timely filing. The earlier Division Bench decisions recognised that late filing of such forms is not barred after assessment, provided the dealer explains the delay and satisfies the authority about sufficient cause. The assessment order, by itself, does not prevent consideration of subsequently produced forms.

Conclusion: The dealer is entitled to have the belated C Forms and F Forms considered if sufficient cause for the delay is established; the refusal to treat the matter as closed merely because assessment was completed is not sustained.

Issue (ii): whether the assessment order could be corrected for arithmetical or clerical mistakes pointed out by the dealer.

Analysis: The assessment order disclosed discrepancies in the turnover figures, and the objections raised by the dealer were of a nature capable of being treated as arithmetical or clerical mistakes. Such mistakes are required to be examined and corrected by the assessing authority on consideration of the dealer's objections, rather than being left unaddressed on the ground that an appeal alone was the remedy.

Conclusion: The assessing authority must consider and correct the arithmetical or clerical mistakes in the assessment order after examining the objections raised by the dealer.

Final Conclusion: The writ petition succeeded to the extent that the assessing authority was directed to consider the delayed statutory forms on the showing of sufficient cause and to rectify the apparent clerical or arithmetical errors in the assessment, with interim protection from recovery until those exercises are completed.

Ratio Decidendi: Where a taxing rule expressly permits extension of time on sufficient cause, belated statutory forms may be entertained even after assessment, and apparent clerical or arithmetical errors in an assessment can be corrected by the assessing authority on proper consideration of objections.

---