Specific questions of law alone may be referred; unargued issues are excluded, while the refund-date issue was consolidated.

A reference to the High Court must be confined to a specific question of law arising from and dealt with in the impugned order; a broad challenge or an issue not canvassed in the appeal will not be referred. Applying that principle, the general first question was rejected as insufficiently specific, and the fourth question was declined because the supporting Special Bench point had not been argued or considered below. The refund dispute under Rule 11 of the Central Excise Rules, 1944 was narrowed into one consolidated question on whether the declaration date was the relevant date for refund claims, and only that reformulated issue was referred.

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Issues: Whether questions not specific on any point of law or not dealt with in the appeal could be referred to the High Court, and whether the question of the relevant date for refund under Rule 11 of the Central Excise Rules, 1944 could be framed for reference.

Analysis: Question 1 was treated as a general challenge to the appellate order and not as a specific question of law. Question 4 was declined because the later Special Bench decision relied upon by the applicant had not been canvassed in the appeal and had not been dealt with in the impugned order. The controversy arising from Questions 2 and 3 was compressed into a single question concerning whether the date of declaration was the relevant date for refund claims under Rule 11.

Conclusion: No reference was made on Questions 1 and 4, and one consolidated question was referred to the High Court on the refund issue.

Final Conclusion: The application was disposed of by declining reference on two questions and referring a single reformulated question on the refund limitation issue.

Ratio Decidendi: A reference lies only on a specific question of law arising from and dealt with in the order under challenge, and a broader or unargued issue will not be referred.

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