Form 27C declaration burden lies on purchaser; seller need not independently verify genuineness once statutory filing is complete.

Section 206C(1A) read with Rule 37C places the declaration burden in Form 27C on the purchaser, while the seller's role is to complete Part II and forward the form to the revenue within time. The text states that, once Part I is duly signed by the declarant and Part II is duly signed by the seller and submitted, the statutory scheme does not require the seller to independently verify the genuineness of the purchaser's declaration or the purchaser's end-use status. On that basis, the Revenue's contrary view was held inconsistent with the provision and prescribed form, and no substantial question of law was found to arise under section 260-A.

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Issues: Whether, under section 206C(1A) of the Income-tax Act, 1961 read with Rule 37C of the Income-tax Rules, 1962, the seller was required to verify the genuineness of the purchaser's declaration in Form 27C, and whether any substantial question of law arose in the appeal under section 260-A of the Income-tax Act, 1961.

Analysis: The declaration contemplated by section 206C(1A) and Rule 37C is to be furnished and verified by the purchaser in Form 27C. Once Part I of Form 27C is duly filled and signed by the declarant and Part II is duly filled and signed by the seller and forwarded to the revenue authorities within time, the statutory scheme does not cast any further verification burden on the seller. The Court held that the Revenue's contention that the seller must independently verify the truthfulness or end-user status of the buyer is contrary to the language of the provision and the prescribed form. On that basis, no substantial question of law arose for consideration under section 260-A.

Conclusion: The appeal did not disclose any substantial question of law and the demand could not be sustained against the assessee on the alleged failure to verify the purchasers' declarations.

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