Reasonable verification under excise rules and the scope of the supplier-identity obligation were held to raise a referable question of law.

Rule 173Q(1)(bb) of the Central Excise Rules, 1944, read with its Explanation, was understood to require an assessee to take reasonable steps to verify the identity and address of the manufacturer or supplier, with verification capable of being satisfied by personal knowledge, a familiar certifying signature, or a certificate from the jurisdictional Superintendent of Central Excise. Where gate passes moved through intermediary hands and the original manufacturer was not directly verifiable, prior Tribunal reasoning treated exact verification as impracticable. The reference application was therefore held to raise a substantial question of law on the scope of this obligation, and the matter was referred to the High Court under Section 35G(1) of the Central Excise Act, 1944.

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Issues: Whether the obligation under Rule 173Q(1)(bb) of the Central Excise Rules, 1944, read with its Explanation, required the assessee to verify the identity and address of the manufacturer or supplier through reasonable steps, and whether the question of law arising from the Tribunal's order should be referred to the High Court under Section 35G(1) of the Central Excise Act, 1944.

Analysis: The order under reference had followed earlier Tribunal decisions and treated it as impracticable to expect the assessee to verify the genuineness of the original manufacturer where gate passes had passed through intermediary hands and the supplier was located elsewhere. The Reference Application raised a substantial question on the scope of the statutory obligation, and the order recognized that the reasonable steps contemplated by the Explanation included satisfaction through personal knowledge, a familiar certifying signature, or a certificate issued by the jurisdictional Superintendent of Central Excise.

Conclusion: The question of law was held to arise and the matter was referred to the High Court.

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