Judgment :- V. RAMASWAMI, J. In this revision petition, two points have been raised by the petitioners. In respect of the asst. yr. 1963-64, they claimed that a turnover of Rs. 2, 12, 621.16 which represented second inter-State sales of declared goods effected by transfer of documents of title when the goods were on movement from this State to another was not liable to tax on the ground that S. 15 prohibited the levy. It is not in dispute that the transaction is not exempted under S. 6(2). The point raised is similar to the one which we decided in T. C. No. 258 of 1970 and that decision, we have held that there was nothing in S. 15 which prohibited the turnover of this character being subjected to levy under the Central ST Act. The order of the Tribunal, therefore, in respect of this disputed turnover is confirmed. 2. The second item of dispute related to a turnover of Rs. 33, 644.14. The exemption under S. 6(2) claimed by the petitioners in respect of this turnover was rejected by the Tribunal on the ground that the Form E-1 Certificates and the Declarations in Form C were produced by the petitioners only before the Tribunal and that therefore they could not be received. The learned counsel for the petitioners pointed out that before the AO they asked for time of 15 days for production of these form but the AO did not give them the time and proceeded to assess. Before the AAC, the petitioners produced these forms but the AAC held that there was no provision to entertain in forms at the stager of appeal and that therefore he refused to receive them. As already stayed, the petitioners produced the same before the Tribunal, but the Tribunal refused to consider the same on the ground that there is no evidence to show that they were filed before tan returned by the AAC. This Court had held in a number of cases that an assessee could produce the certificates and declarations within a reasonable time, and that production. even before the AAC or the Tribunal, in appropriate cases, could be considered as reasonable. In the present case, we find that the assessee asked for time of 15 days before the AO to produce the certificates but that was not granted. The same were produced in the appeal. even before the AAC or the Tribunal, in appropriate cases, could be considered as reasonable. In the present case, we find that the assessee asked for time of 15 days before the AO to produce the certificates but that was not granted. The same were produced in the appeal. The AAC, without considering the question whether the non-production of the certificates and declarations at the earlier stage lacked bona fides or that there was any unreasonable delay in the production of the same, simply stated that he had no power to receive them. Even the Tribunal has not given any finding whether there was any unreasonable delay in the production of the certificates even if the petitioners had not produced the same before the Appellate Authority. We are satisfied that on the facts and circumstances of this case, the Form E-1 certificates and the 'C' declaration's produced in respect of the disputed turnover should have been entertained by the Tribunal and considered the liability to tax with reference to these certificates. Since the Tribunal has not considered them on the merits, we have no option but to set aside that portion of the Tribunal's order relating to Rs. 33, 644.14 and remand the matter to the Tribunal for fresh consideration in the light of the E-1 Certificates and the C From Declarations produced by the petitioners. There will be an order accordingly. Since on the main question of the liability of the turnover of Rs. 2, 12, 621-16, the petitioners failed, they will pay the costs of the Revenue. Counsel's fee Rs. 250/-.