Civil court jurisdiction barred where excise law provides a complete statutory remedy scheme for assessment, appeal and revision.

A fiscal statute that creates rights and liabilities and provides a complete machinery of assessment, refund, appeal and revision excludes civil court jurisdiction over disputes within that scheme. Even if the excise authority is said to have erred or misconstrued the law, that does not by itself confer jurisdiction on a civil court where the authority was competent to decide the issue. Questions on excise liability, removal of goods and application of the rules were therefore for the statutory authorities, and the availability of statutory remedies, with further constitutional review, barred the civil suit.

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Issues: Whether the civil court had jurisdiction to entertain a suit challenging excise duty and penalty orders when the Central Excises and Salt Act and the Rules provided a statutory machinery of appeal and revision.

Analysis: The statutory scheme was treated as a complete code governing assessment, refund, appeal and revision in excise matters. Where the competent excise authority has jurisdiction to decide the questions arising before it, even an erroneous decision or misinterpretation does not by itself create civil court jurisdiction. The availability of remedies under the Act, coupled with the finality attached to orders of the excise authorities and the possibility of further constitutional review, excludes recourse to a civil suit. The court also noted that questions concerning liability, removal of goods, and the applicability of the relevant excise rules were matters for determination by the statutory authorities.

Conclusion: The civil court's jurisdiction was barred, and the suit could not be maintained.

Ratio Decidendi: Where a fiscal statute creates rights and liabilities and provides a complete hierarchy of remedies for their determination and correction, the civil court's jurisdiction is excluded even if the statutory authority is alleged to have erred in deciding the matter.

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