Substantial compliance with declaration requirements upheld where classification list and departmental permission satisfied the rule's purpose.

Furnishing the relevant particulars in the classification list, together with departmental permission to send goods to job workers, was treated as substantial compliance with the declaration requirement under Rule 57G. The Tribunal did not hold that the Rule 57F(2) application itself amounted to a declaration; rather, it relied on the combined effect of the available documents to conclude that the statutory purpose had been met. On that footing, the Revenue's proposed questions were academic and no referable question of law arose. The refusal to state a case was therefore upheld.

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Issues: Whether the information furnished in the classification list and the permission granted for sending goods to job workers constituted substantial compliance with Rule 57G, so as to justify refusal of reference on the proposed questions of law.

Analysis: The Tribunal had not held that the application under Rule 57F(2) was itself a declaration under Rule 57G. Its finding was that the assessee had furnished the relevant particulars through the classification list and the departmental permission, which amounted to substantial compliance with the requirement of filing a declaration. In these circumstances, the questions framed by the Revenue were treated as academic, and no infirmity was found in the Tribunal's refusal to state a case.

Conclusion: The proposed reference was rightly declined, as the record disclosed substantial compliance with the requirement of declaration and no referable question of law arose.

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