Area-based excise zoning for tea remained unchanged after district bifurcation, rejecting a lower residuary duty claim.

Area-based excise zoning for tea depended on the territorial area covered by each zone, not on the later administrative name of the district. Where a district was created by bifurcation from an area already placed in a specified zone, that area did not move into the residuary zone merely because the notification was not amended to name the new district. The classification remained unchanged for duty purposes, and the claim for the lower residuary rate was rejected.

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Issues: Whether, for determining the rate of excise duty on tea, a district that came into existence after bifurcation of an earlier district could be treated as falling in the residuary zone merely because the excise notification had not been amended to mention the new district by name.

Analysis: The zoning under the excise notification was area-based, and the district names used in the notification were only descriptive of the territorial area comprised in each zone. The mere creation of a new district out of an area already included in a specified zone did not take that area out of the original zone. Non-amendment of the notification after bifurcation did not alter the zone-wise classification for duty purposes.

Conclusion: The new district continued to fall within the original zone, and the claim to a lower rate under the residuary zone was rejected.

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