1982 (11) TMI 163

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....he assessee not before the first assessment was completed, but at the stage of appeal before Appellate Assistant Commissioner. The Appellate Assistant Commissioner did not entertain the C forms. On further appeal, the Tribunal held that the assessee had not established that it was prevented by sufficient cause from filing the C form declaration within the time limited, namely, before completion of....

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....ssing authority alone. It was also further held that the extension of time by the appellate authority as well as the assessing authority was not to depend upon the enquiry as to whether the assessee was prevented by sufficient cause from filing the C form declarations before the assessment was over, but whether, on a consideration of the entire circumstances, the appellate authority could consider....