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Issues: Whether instant tea manufactured and exported by the assessee falls within the definition of tea under Section 3(n) of the Tea Act, 1953 so as to attract cess under Section 25 of the Tea Act, 1953.
Analysis: The statutory definition covered the plant Camellia sinensis and all varieties of the product known commercially as tea made from its leaves. Instant tea was found to satisfy both elements because it was commercially known as tea and was produced from the leaves of Camellia sinensis. The manner of preparation, the fact that it could be used in cold water, and its process of manufacture did not take it outside the statutory definition. Once it fell within Section 3(n), cess under Section 25 necessarily applied. Reliance on other enactments was held unnecessary where the Tea Act itself provided a specific definition.
Conclusion: Instant tea is tea within Section 3(n) of the Tea Act, 1953 and is liable to cess under Section 25 of the Tea Act, 1953.
Final Conclusion: The Revenue succeeded, the contrary view of the Tribunal was set aside, and the demand of cess was sustained.
Ratio Decidendi: Where a statute defines tea to include all varieties commercially known as tea and made from the leaves of Camellia sinensis, a product marketed as instant tea remains within that definition notwithstanding its form, preparation, or mode of consumption.