GOVERNMENT OF INDIA vs CITEDAL FINE PHARMACEUTICALS MADRAS &ORS.ETC. ETC.

The Supreme Court held that Rule 12 of the Medicinal and Toilet Preparations (Excise Duties) Rules, 1956, is valid and does not create additional liability for manufacturers but provides a mechanism for recovery of unpaid duties as per Section 3 of the Medicinal and Toilet Preparations (Excise Duties) Act, 1955. The Court clarified that the absence of a specified period for recovery does not violate Article 14 of the Constitution, as recovery must occur within a reasonable time based on case facts. The High Court's ruling that the Rule is ultra vires was overturned, affirming the authority's power to issue demand notices for unpaid duties.