Excise duty on beer applies only when finished beer is removed from storage, not at the wort stage.

Excise duty on beer was held not to arise at the wort stage because wort was only an intermediate, non-alcoholic stage in manufacture and not an alcoholic liquor for human consumption. The statutory charging scheme linked liability to the finished product and its removal from the distillery, brewery, warehouse, or other place of storage. Duty became payable only when the beer had reached the consumable stage and was received in the bottling tank for removal from storage. The manufacturer therefore succeeded.

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Issues: Whether beer became exigible to excise duty at the wort stage during manufacture, or only when it emerged as the finished product and was removed from storage.

Analysis: The Act contemplated levy on excisable article in the form of alcoholic liquor for human consumption, and the charging scheme linked payment of duty to removal from the distillery, brewery, warehouse, or other place of storage. Beer at the wort stage contained no alcohol and was only an intermediate stage in the brewing process. The Court applied the principle that excise duty on alcoholic liquor is attracted only when the final product reaches the stage of human consumption, and not on raw material or an in-process intermediate. On the statutory scheme, duty became payable when the finished beer was received in the bottling tank and sought to be removed from the place of storage or warehouse.

Conclusion: Excise duty was not leviable at the wort stage; it was leviable only on the finished beer when removed from storage or warehouse, and the appellant succeeded.

Ratio Decidendi: Excise duty on alcoholic liquor for human consumption is attracted only when the product becomes a finished, consumable article and is removed from the statutorily relevant place of storage, not while it remains an intermediate stage in manufacture.

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