HC rejected applicant's reference application under Chhattisgarh...

HC rejected applicant's reference application under Chhattisgarh Value Added Sales Tax Act, 2005. Applicant failed to produce mandatory Form 3 for eight years to discharge burden of proof regarding sub-contractor's tax payment on turnover. Court held that reference jurisdiction is purely advisory and consultative, requiring substantial question of law under Section 55(2). Payment of tax by sub-contractor remained disputed question of fact, not law, as Form 3 was not produced within statutory timeframe. No statutory duty exists compelling Department to grant indefinite extensions for Form 3 submission. Absence of Form 3 negated double taxation concerns. Court distinguished between questions of fact versus law, concluding no legal question arose warranting HC's adjudication in reference proceedings.