JUDGMENT :

JOYMALYA BAGCHI, J.

1. Petitioner has assailed the endorsement, dated 15.12.2020 of the 1st respondent rejecting the declarations in Form ‘C’ which were obtained by it in the year 2020 and consequentially refusing to reopen the Assessment Order dated 4.12.2015 in respect of the Assessment Year 2012-13.

2. Learned Counsel for the Department submit that the authorities had no power to reopen the proceedings after lapse of four years, in view of Section 21(4) of the Andhra Pradesh Value Added Tax Act, 2005 (‘the A.P. VAT Act’ for brevity).

3. We have considered the materials on record.

4. The declaration in Form ‘C’ or Form ‘F’ or the certificate in Form ‘E-1’ or Form ‘E-II’ under the A.P. VAT Act is to be filed within the time frame as envisaged in Rule 12(7) of the Central Sales Tax (Registration and Turnover) Rules, 1957 (‘the Rules’ for brevity), which reads as follows:

“12(7): The declaration in Form ‘C’ or Form ‘F’ or the certificate in Form ‘E-l’ 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 pers