Excise Duty Not Applicable to Blended Fuel Products

The Court held that the addition or blending of Multi-Functional Additives with Motor Spirit and duty paid High Speed Diesel did not result in the emergence of new products attracting fresh excise levy. It was determined that the essential characteristics of the products did not significantly change, and the resulting blended product maintained the same specifications as the original. Citing previous rulings, the Court dismissed the appeals, noting a recent decision against the revenue in a similar case.

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Issues involved:
The issue involved in this case is whether the addition or blending of Multi-Functional Additives with Motor Spirit (MS) and duty paid High Speed Diesel (HSD) results in the transformation of those products into new products attracting fresh excise levy.

Summary:

Issue 1: Transformation of products for fresh excise levy
The Tribunal and the Court considered whether the addition or blending of Multi-Functional Additives with Motor Spirit (MS) and duty paid High Speed Diesel (HSD) results in the emergence of new products attracting fresh excise levy. Previous rulings and judgments were cited, emphasizing that unless the essential characteristic of the article of the emerging product changed significantly, mere blending or addition leading to negligible changes would not constitute the manufacture of a new product. The product emerging after blending was found to conform to the same specifications as the original product. The Court noted that this issue had been recently decided against the revenue in a previous case.

Decision:
Based on the above position, the Court concluded that the appeals must fail, and accordingly, they were dismissed.

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