JUDGMENT : JOYMALYA BAGCHI, J. 1. Order dated 28.1.2019 passed by the 1st respondent refusing to permit the petitioner to file ‘F’ forms in respect of interstate transfer to his branch unit at Karnataka and consequentially reopen assessment proceedings on such score has been assailed in this writ petition. 2. Learned Counsel for petitioner submits that his business had closed down and he had left the place of business. Accordingly, he had no notice of the assessment proceedings including the assessment order dated 27.3.2015 passed therein by the 1st respondent in respect of assessment year 2011-2012 following the Best Judgment Method. 3. It is further contended only in 2018 upon recovery proceedings being initiated under the Revenue Recovery Act, the petitioner came to know of the aforesaid assessment order and thereafter made endeavours to collect the ‘C’ forms and ‘F’ declaration forms from the branch office and on 14.1.2019 made a representation to the 1st respondent seeking permission to submit 12 ‘F’ forms with regard to interstate transfer and to reopen the assessment proceedings and give exemption by taking into account the aforesaid ‘F’ declaration forms. 4. He relied on decisions of the erstwhile High Court at Andhra Pradesh in M/s. Godrej Agrovet Limited and Another vs. The C.T.O. Eluru, (2005) 41 APSTJ 92, as well as M/s. Hyderabad Industries vs. State of Andhra Pradesh, (1991) 13 APSTJ 181, in support of his contentions. However, the 1st respondent, by the order impugned, dismissed the prayer of the petitioner on the ground the factual matrix of the case did not disclose sufficient cause to permit him to file the ‘F’ forms at such belated stage. 5. Mr. Y.N. Vivekananda, learned Government Pleader for Commercial Tax submits that the assessee had intentionally not participated in the assessment proceedings and accordingly assessment order was passed on 27.3.2015 by using Best Judgment Method. The assessee kept silent till steps were taken to recover the tax liability under the Revenue Recovery Act and thereafter made the aforesaid application which was rightly turned down. He submits no sufficient cause permitting enlargement of limitation period envisaged under Rule 12(7) of the Central Sales Tax (Registration and Turnover) Rules, 1957 (hereinafter, referred to as ‘the CST Rules’) is made out in the factual matrix of the case. He submits no sufficient cause permitting enlargement of limitation period envisaged under Rule 12(7) of the Central Sales Tax (Registration and Turnover) Rules, 1957 (hereinafter, referred to as ‘the CST Rules’) is made out in the factual matrix of the case. It is further submitted that the ratio in M/s. Godrej Agrovet's case (supra), is inapplicable inasmuch as the said judgment was delivered interpreting the pre-amended rules where a different period of limitation for submission of 'F' forms was prescribed. 6. We have considered the rival submissions of the parties. 7. Rule 12(7) of the Central Sales Tax (Registration and Turnover) Rules, 1957 (as amended in 2005 and applicable to the present case) reads as follows: “The declaration in Form-C of Form-F or the certificate in Form E-I or Form E-II shall be furnished to the prescribed authority within three months after the end of the period to which the declaration or the certificate relates. PROVIDED that if the prescribed authority is satisfied that the person concerned was prevented by sufficient cause from furnishing such declaration or certificate within the aforesaid time, the authority may allow such declaration or certificate to be furnished within such further time as that authority may permit.” Pre-amended Rule 12(7) of the CST Rules reads as follows: “The declaration in Form-C or Form-F or the certificate in Form ‘E-I’ or ‘E-II’ shall be furnished to the prescribed authority upto the time of assessment by the first assessing authority: Provided that if the prescribed authority is satisfied that the person concerned was prevented by sufficient cause from furnishing such declaration or certificate within the aforesaid time, that authority may allow such declaration or certificate to be furnished within such further time as that authority may permit.” 8. As per the amended rule, the assessee is to furnish the requisite declaration/certificate within three months of the assessment year, while in the pre-amended Rule, he had option to file the declaration/certificate in the course of the assessment proceedings whenever the same was initiated as per law. In both the situations, however, the proviso to the Rule permitted the prescribed authority to condone the delay in furnishing declaration/certificate provided sufficient cause is shown. In both the situations, however, the proviso to the Rule permitted the prescribed authority to condone the delay in furnishing declaration/certificate provided sufficient cause is shown. Analysis of the aforesaid amendment to the statutory scheme would show the time frame for submission of the declaration/certificate has been curtailed from the date of assessment to three months beyond the assessment year to which the declaration/certificate relates. Hence, under the amended scheme, the dealer in order to avail the benefit of the proviso to the Rule must explain the delay from the date of expiry of the truncated time frame i.e. three months beyond the assessment year and not from the date of the assessment proceedings. 9. Instant case relates to the assessment year 2011-2012. Hence, the dealer was required to file the declaration forms within June, 2012 as per the amended rule. Admittedly, he failed to submit the declaration forms within the said period. In 2015 show-cause notice was issued and ex-parte assessment order was passed on 27.3.2015, as the petitioner did not participate in the said proceedings. Thereafter, demand notice dated 9.11.2015 was issued and as the petitioner did not pay the tax liability, notice of attachment of land was issued on 9.2.2018. 10. It is contended on behalf of the petitioner that his business had closed down due to heavy losses, hence the plant was closed and he was unaware of notices including assessment order passed by the tax authorities. Only upon steps being taken for attachment of land, he became aware of the assessment proceedings. Thereafter, he prayed for enlargement of time to submit ‘F’ declaration forms with regard to interstate transfer between his Head Office at Hindupur and Branch Office at Bangalore and to reopen the assessment order on such score. 11. 1st respondent, however, was of the opinion that the declaration forms were in relation to interstate movement of goods between branches of the same firm and therefore closure of the business could not be a ground for belated submission of the forms, hence such prayer was rejected. We are in agreement with the finding of the 1st respondent. No doubt, the tax authorities have jurisdiction in appropriate cases to permit the dealer to submit declaration forms beyond three months from the period to which the declaration relates, however, to do so, the dealer must satisfy the authority that there was sufficient cause for the delay. We are in agreement with the finding of the 1st respondent. No doubt, the tax authorities have jurisdiction in appropriate cases to permit the dealer to submit declaration forms beyond three months from the period to which the declaration relates, however, to do so, the dealer must satisfy the authority that there was sufficient cause for the delay. 12. As discussed above, the dealer was required to submit 'F' declaration forms with regard to interstate branch transfer by June, 2012, but he failed and neglected to do so. Only after the recovery proceedings being initiated in respect of assessment order, he approached the 1st respondent in 2019 for enlargement of time to submit the declaration forms. 13. The plea of closure of business for the delay in submission of declaration forms is extremely facile and evasive. The forms related to interstate transportation of goods between the Head office of the assessee to its branch office in the assessment year 2011-2012. Under such circumstances, it is not understood why the assessee failed to obtain the declaration forms from its branch office and submit the same since 2012. Even if one accepts the assessee's version that he was unaware of the assessment proceedings and the order passed therein in 2015 due to closure of business, it does not give sufficient explanation for its failure to furnish declaration forms since 2012. We are not unmindful that the expression 'sufficient cause' requires to be liberally constituted and a reasonable and justifiable explanation would suffice. However, for the cause to be sufficient, explanation offered must provide justification for the entire period during which the assessee had failed to furnish forms i.e. from 2012 to 2019 as in the present case. 14. While the proviso to Rule 12(7) of the CST Rules gives opportunity to the dealer to make belated submission of declaration/certificate when sufficient cause is shown, the said proviso cannot be permitted to be abused by an indolent and indifferent dealer, who at a belated stage approaches the authorities without proper cause for submission of the declarations/certificates and seeks to reopen a concluded assessment proceedings on such score. 15. In the light of the aforesaid discussion, we are of the view the factual matrix of the case does not disclose any justifiable or sufficient cause for the inordinate delay in submission of the declaration forms. 15. In the light of the aforesaid discussion, we are of the view the factual matrix of the case does not disclose any justifiable or sufficient cause for the inordinate delay in submission of the declaration forms. Thus, we are of the opinion that there is no illegality or irregularity in the impugned order passed by the assessing authority. 16. The writ petition is, accordingly, dismissed. 17. No order as to costs. 18. As a sequel, miscellaneous petitions, if any, pending in the writ petition shall stand closed.