https://www.taxtmi.com/caselaws?id=783601 Packaged drinking water cleared by one unit was held not assessable on MRP under s.4A Central Excise Act, 1944 because the record lacked any positive evidence of mineral addition/demineralisation to classify it as "mineral water" covered by the relevant MRP notifications; consequently, the duty demand founded on s.4A valuation was set aside. For SSI exemption, clubbing of clearances across units could not sustain the demand since Revenue failed to establish any material differentiator or tax-avoidance device, and consistent Tribunal rulings for other units required similar treatment; hence no duty arose on that basis. Extended limitation and penalties under s.11AC/Rule 25 and personal penalty under Rule 26 were rejected for absence of fraud/suppression or mens rea in an interpretational dispute; confiscation and redemption fine were also set aside. Appeal allowed. en-us Tue, 16 Dec 2025 00:00:00 +0530 Thu, 18 Dec 2025 16:35:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783601 Packaged drinking water cleared by one unit was held not assessable on MRP under s.4A Central Excise Act, 1944 because the record lacked any positive evidence of mineral addition/demineralisation to classify it as "mineral water" covered by the relevant MRP notifications; consequently, the duty demand founded on s.4A valuation was set aside. For SSI exemption, clubbing of clearances across units could not sustain the demand since Revenue failed to establish any material differentiator or tax-avoidance device, and consistent Tribunal rulings for other units required similar treatment; hence no duty arose on that basis. Extended limitation and penalties under s.11AC/Rule 25 and personal penalty under Rule 26 were rejected for absence of fraud/suppression or mens rea in an interpretational dispute; confiscation and redemption fine were also set aside. Appeal allowed. Case-Laws Central Excise Tue, 16 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783601