Single-point cess on manufactured paper prevents double levy when the same paper is later used as wrapping material.

Section 9 of the Industries (Development and Regulation) Act, 1951 imposes cess on goods manufactured or produced in a scheduled industry, and the charge arises on completion of manufacture or production. Once cess is paid on a given quantity of paper, the same goods cannot be subjected to cess again merely because they are later used as wrapping material or their form changes. The provision does not authorise a multi-point levy on the same goods, and the Explanation only clarifies valuation methodology. Cess on wrapping paper is therefore confined to a single levy on the manufactured quantity.

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Issues: Whether cess under Section 9 of the Industries (Development and Regulation) Act, 1951 could be levied twice on the same quantity of paper, once at the stage of manufacture and again when the same paper was later used as wrapping material.

Analysis: Section 9 levies cess on goods manufactured or produced in a scheduled industry. The liability fastens on completion of manufacture or production, and once cess is paid on the goods so produced, the same quantity cannot be subjected to cess again merely because its form changes or it is later used as a component or packing material. Nothing in the Act authorises a multi-point levy on the very same goods. The Explanation only clarifies the manner of valuation and does not create a second charge.

Conclusion: The cess could be levied only once on the wrapping paper, and the Revenue was not entitled to a second levy on the same quantity after its use as wrapping material.

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