The issue was whether the responsibility of verification in Form 27C lies with the seller or the purchaser. The Revenue argued that the seller must verify the declaration furnished. The High Court rejected this contention, holding that the Act and Rules make it explicit that the declarant is the purchaser who furnishes the verified form to the seller. Neither S. 206C(1A) nor Rule 37C imposes any duty on the seller to verify the correctness of the declaration. Relying on Atibir Industries Co. Ltd. v. Central Coalfields Ltd(WP No. 46 of 2018 dt.3-12-2018  (Jharkhand) (HC) the Court reiterated that the obligation rests squarely on the purchaser and not the seller. Since the Revenue’s argument was contrary to the statutory scheme, no substantial question of law arose.