Double excise on separately dutiable wrapping paper was impermissible after duty had already been paid on that material.

Excise duty could not be levied a second time on wrapping paper that had already been assessed as wrapping paper merely because it was later used internally to pack other paper goods and its value was included in the packed goods' assessable value. The charging provision made manufacture or production the taxable event, while valuation provisions operated only as machinery. The wrapping paper retained its separate identity as an excisable commodity, and packing it did not make its value part of the manufacture of the inner paper. Its cost could not be loaded again into the assessable value after duty had already been paid on it.

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Issues: Whether excise duty could be levied again on wrapping paper, already assessed as wrapping paper, when that paper was used internally for packing other varieties of paper and its value was included in the assessable value of the packed goods.

Analysis: Section 3 of the Central Excises and Salt Act, 1944 makes manufacture or production the taxable event, while Section 4 and the packing explanation operate only as machinery for valuation. The wrapping paper remained a separately excisable commodity and its use as packing did not alter its identity or convert the later packing operation into part of manufacture of the inner paper. The assessable value of excisable goods cannot be loaded with post-manufacturing costs or with the value of the same goods twice over. Reading Section 4 consistently with the charging provision, the cost of wrapping paper cannot again be included in the value of the packed paper once duty has already been paid on that wrapper paper at the tariff rate applicable to it.

Conclusion: The levy of excise duty again on the value of wrapping paper, after it had already suffered duty as wrapping paper, was impermissible and the assessee succeeded.

Ratio Decidendi: Excise duty under the charging provision cannot be imposed twice on the same excisable goods, and a separately dutiable packing material cannot be included again in the assessable value of the packed goods after duty has already been paid on it.

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