Purified water without added mineral salts is not mineral water for excise classification under the tariff entry.

Treated water purified with lime, bleaching powder, soda, ferro-sulphate and filtration, but with no addition of mineral salts or gases, remains purified water and does not become mineral water for excise classification. The applicable circular was read as treating added mineral salts as the relevant factor for attracting duty under sub-heading 2201.90. On that basis, the product was held non-excisable as mineral water, the appellate classification was sustained, and the Revenue's challenge was rejected.

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Issues: Whether treated pure water, after purification without addition of mineral salts, was classifiable as mineral water under sub-heading 2201.90 and liable to excise duty.

Analysis: The product was subjected to treatment with lime, bleaching powder, soda, ferro-sulphate and filtration to remove impurities and microorganisms, but no mineral salts or gases were added at any stage. The applicable circular clarified that only where mineral salts are added to treated water does the resultant product become mineral water and attract duty. On the admitted process, the product remained purified water and not mineral water for tariff purposes.

Conclusion: The product was not excisable as mineral water under sub-heading 2201.90 and the Revenue's challenge failed.

Final Conclusion: The classification adopted by the appellate authority was sustained, and the Revenue's appeal was rejected.

Ratio Decidendi: Treated water that is merely purified without addition of mineral salts does not become mineral water for excise classification and remains non-excisable under the relevant tariff entry.

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