Jagannadha Raju, J.

1. At the instance of the revenue, a single reference is made relating to a batch of 21 reference applications. The question of law involved is the same in all the cases. The question referred by the Tribunal is as follows:

"Whether on the facts and circumstances of the case, it is in law to hold that for the purpose of determining the eligibility for rebate of duty on tea exported in terms of Notification No.166/81 dated 23-9-1981, filing an application for registration under Clause.1 of Appendix to the aforesaid Notification was not a mandatory requirement to be done prior to the export of tea."

2. Obviously the question has not been framed in a straight forward simple manner in which it is easy to understand. There appears to be some typographical errors as well as some grammatical errors. If we recast the question in simple English, it would read as follows:

"Whether, on the facts and in the circumstances of these cases, to determine the question of eligibility for rebate of duty on blended tea exported in terms of Notification No.166/81 dated 23-9-1981, it is mandatory that the registration should precede the export or whether it is sufficient if th