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Issues: Whether excise duty was leviable on goods manufactured before the 1980 amendment to Section 2(f) of the Central Excises and Salt Act, 1944 and Tariff Item No. 27(f), but removed from the factory after the amendment came into force.
Analysis: The governing principle is that the taxable event in central excise is manufacture or production of goods, not their removal. Where the goods were fully manufactured before the relevant amendment, subsequent clearance from the factory does not attract the amended levy merely because removal took place later.
Conclusion: The duty was not payable on the goods manufactured before the amendment, and the appeal failed.