Collector Of Central Excise, Patna vs Tata Iron & Steel Co. Ltd.

The court addressed whether goods manufactured before a rate increase in special excise duty but cleared after such increase should be taxed at the old or new rate. The court ruled that since special excise duty is an annual levy that resets on March 1st, goods manufactured in the preceding period are deemed cleared on the last day of that period. Consequently, the rate prevalent at the time of manufacture, rather than the rate at the time of actual clearance, applies.