MRP-based excise valuation follows the declared price on each packet; highest regional MRP cannot be used alone.

Under the MRP scheme for repacked consumer products, excise duty is assessed on the retail price actually declared on the container or packet. Where each packet for a particular region bore only one MRP, the highest of different region-wise MRPs could not be adopted merely because other regions carried different prices. The larger-bench principle applied only when more than one MRP appeared on the same container or packet under Explanation 2 to Section 4A. On that basis, the impugned order was sustained and the Revenue's appeal failed.

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Issues: Whether, where each packet bore only one Maximum Retail Price for the relevant region, excise duty under the MRP scheme had to be assessed on the highest declared MRP merely because different MRPs were declared for different regions.

Analysis: The goods were repacked consumer products covered by MRP-based valuation under Section 4A. It was undisputed that each container or packet for a particular region carried only one retail price. The governing principle, as applied from the Larger Bench decision, is that assessment follows the retail price actually declared on the container or packet, and the maximum of different MRPs is relevant only where more than one MRP appears on the same container or packet under Explanation 2 to Section 4A.

Conclusion: The highest MRP could not be adopted merely because the respondent had region-wise MRPs. The impugned order was correctly sustained and the Revenue's appeal failed.

Ratio Decidendi: Under Section 4A, where a container or packet bears only one retail price, duty is to be assessed on that declared price; the highest of multiple MRPs is relevant only when more than one MRP appears on the same container or packet.

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