Excise duty liability attaches on manufacture, not removal, and prospective exemption withdrawal does not operate retrospectively.

Excise duty under the charging provision is treated as a levy on manufacture or production, so liability attaches when the goods are completed and not when they are removed from the factory. Provisions dealing with assessment, rate, and the time and manner of payment operate only after that liability has accrued. A prospective withdrawal of exemption does not retrospectively fasten duty on goods already manufactured before the effective date. On that basis, the request for a certificate to appeal was rejected because no substantial question of law of general importance was shown.

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Issues: Whether, for purposes of grant of certificate to appeal, excise duty under the charging provision arose on manufacture or production of the goods, and not on their removal from the factory, where the exemption was withdrawn prospectively.

Analysis: Excise duty was treated as a levy on manufacture or production under the charging provision, so the material time for attaching liability was the completion of manufacture or production. The provisions governing assessment, rate, and the time and manner of payment dealt with the rate prevailing on removal only after liability had arisen. The withdrawal of exemption was prospective and did not operate retrospectively so as to fasten duty on goods already manufactured before the effective date. On that footing, the case did not disclose any substantial question of law of general importance warranting a certificate.

Conclusion: The petition for certificate of fitness was rejected, and the levy was held to attach on manufacture or production, not on removal, in the circumstances considered.

Final Conclusion: The request to carry the matter in appeal to the Supreme Court failed, and the assessee's position on the timing of excise liability was sustained.

Ratio Decidendi: Where excise is imposed for the first time under the charging section, liability arises on manufacture or production, while the provisions concerning removal regulate only the rate and manner of payment after such liability has accrued.

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