proviso to Rule 12(1) was amended during the financial year 2005-06, only with effect from 1.10.2005. As such, even if the Rule is to be strictly construed, till 1.10.2005, there was no requirement for the assessee to submit separate declarations in Form C for different quarters of a financial year, regarding transactions between the same two dealers. The counsel further contends that since the word used in the second proviso is 'may', the same can only be treated as directory and not mandatory. It is in support of the above contention, the the counsel relies on the decision in Cipla Ltd. (supra). We have gone through the above said decision. The above decision relates to the interpretation of Rule 12(5). On a conjoint reading of Rules 12(1) and 12(5), we are of the opinion that the interpretation placed on Rule 12(5) cannot be made applicable to Rule 12(1). Rule 12(1) deals with Form C declaration and even though the word used in the second proviso is 'may', the third proviso to the Rule categorically says that where delivery of goods is spread
