Revised declaration may apply from the amended notification date when parameters remain unchanged and the new basis is satisfied.

A revised declaration for rolling mill parameters may be given effect from the date an amended notification becomes operative where the declaration matches the new statutory basis and there is no allegation that material parameters changed in the intervening period. Here, the declaration made after the amendment was later verified and found substantially correct, so it could reasonably be applied from 1-9-97. The practical effect was that the assessee was entitled to the benefit of the revised ACP from that date.

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Issues: Whether the revised declaration of the rolling mill parameters was required to be given effect from 1-9-97, the date on which the notification was amended and the alternative scheme of taxation based on ACP came into force.

Analysis: The appellants had made the revised declaration on 19-9-97, and the Department later verified it and found it substantially correct. The record disclosed no allegation that the appellants altered the relevant parameters between the date of declaration and the date of verification. In these circumstances, once the notification was amended with effect from 1-9-97 by introducing a different basis for determining the crucial parameters, the revised declaration could reasonably be applied from that date.

Conclusion: The revised declaration was to operate from 1-9-97, and the appellants were entitled to the benefit of the revised ACP from that date.

Ratio Decidendi: Where a revised declaration corresponds to the amended statutory basis and there is no allegation of alteration of material parameters in the intervening period, the declaration may be given effect from the date the amended notification becomes operative.

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