TaxTMI 
TaxTMI 
2022 (6) TMI 140
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....al, vide order dated 27.01.2021, passed by the Excise Commissioner. 3. Admittedly, the petitioner has a remedy of revision against the order dated 27.01.2021, under Section 11 of the Uttar Pradesh Excise Act, 1910 (hereinafter referred to as the Act). However, the present petition was filed directly before this Court, on the plea of lack of jurisdiction. Thus, it has been submitted, the entire quantities of HSMS subjected to Consideration Fee/Pratiphal Shulk' had been imported into the country from M/s William Grant & Sons Distillers Limited, Giravan Distillery, Grangestone Industrial Estate, Girvan, Scotland, United Kingdom (hereinafter referred to as William Grant). Therefore, the said goods fell outside the scope of levy of Excise duty by the State of U.P. Accordingly, the matter was entertained, and Counter Affidavit called. Pleadings are complete. The matter was thus heard. Here, it may be noted, the plea of alternative remedy has not been urged at the stage of final hearing. The State has also sought a decision on merits. 4. Learned counsel for the petitioner states, the petitioner is a duly incorporated company having its distillery at Modi Nagar, Ghaziabad. It first i....
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....y only in case of transportation of such goods from a distillery and not in case of goods dispatched to a distillery. 6. Similarly, in the second transaction, the petitioner sought to import 24596 Bulk litres of HSMS from William Grant. Similar procedures were followed, and similar communications were issued leading to similar result. In that case, against 24596 Bulk litres of HSMS of strength 67.6% v/v, measured by the Custom Authorities of United Kingdom, upon receipt at the petitioner's distillery, the same were found to be 24593 Bulk litres of HSMS of 66.6% strength. Against allowable transit loss 164.82 Alcoholic litres, loss suffered was found to be 248 Alcoholic litres. Thus, 164.82 Alcoholic litres or 385.10 Bulk litres excess loss was found. On 22.09.2018, a second demand notice no.484 was issued demanding Consideration Fee/excise duty/'Pratiphal Shulk' Rs.4,59,385.20. The petitioner filed its reply dated 11.10.2018, to that notice. 7. Thereafter, the date of personal hearing was fixed for 08.05.2019. On 08.07.2019, a common order was passed confirming the demand of Consideration Fee/'Pratiphal Shulk', on excess transit loss at Rs.15,51,042.50, on both transactions (....
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....ms frontier as defined by the Central Government; Section 3(18) of the Act, a corresponding definition of 'export' exists; Section 3(19) of the Act, the word 'transport' means movement from one place to another within the State of Uttar Pradesh; Section 3(20) of the Act, the word 'manufacture' includes every process whether natural or artificial, by which an intoxicant may be produced or prepared and last; under Section 3(22a) of the Act, 'excisable articles' means, any alcoholic liquor for human consumption or any intoxicating drug. 11. Thus, relying on the aforesaid provisions of the Act, it has been vehemently urged, HSMS were imported by the petitioner from William Grant, across the customs frontier of the country, (as defined by the Central Government) namely, the I.C.D., Dadri. They were neither excisable goods nor they were goods produced inside the State of U.P. nor they were brought inside the State of U.P. from any other State within the country. Therefore, by very description of their arrival into the country and/or the State of U.P., from abroad, the goods HSMS were not amenable to Excise duty under the Act. Therefore, they were not liable to ....
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....n of India & Ors., (1999) 8 SCC 744; Kiran Spinning Mills vs Collector of Customs, (2000) 10 SCC 228 and Indian Tourist Development Corporation Limited Through Hotel Ashoka vs. Assistant Commercial Tax & Anr. (2012) 3 SCC 204. In that context, reliance has also been placed on Circular No.50 of 2020 dated 05.11.2020 issued by the Government of India, declaring I.C.Ds. to be "self-contained Customs station". 15. Second, in the alternative, it has been submitted, in any case, the levy of Consideration Fee/'Pratiphal Shulk' may arise under the Act only in the event of transportation loss suffered during, and upon it exceeding, permissible limits, only when that excisable article may be in transit from a distillery. Assuming, HSMS were excisable goods, the excess loss was suffered while those goods were in transit from the ICD, Dadri to the petitioner's distillery. That transaction would fall outside the levy provision even if that provision were to apply. Here, referring to paragraph No. 612 read with paragraph Nos. 613 and 814 of the U.P. Excise Manual (under Chapter-VIII), it has been submitted, those provisions apply only to dispatches made by and from the distillery and ....
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..... Referring to Indian Oil Corporation Limited Vs. State of U.P. & Ors., 2018 (6) ADJ 706, it has been submitted, regulatory provisions cannot be cited to define the custom frontiers under the Act. Merely because Section 60 of the Customs Act permits clearance of goods from a Customs warehouse, it cannot be said - upon clearance/dispatch of goods from such warehouse, the goods first crossed the custom frontier of the country. Those are only facilitative provisions for the benefit of the importer or owner of the goods. The Inland Container Depots (I.C.Ds.) are creatures of statute. They are not determinative of occurrence of the taxable event under the Act. 20. In the present case, undisputedly, the goods landed in the country through the seaport at Gujarat. Therefore, the entry of HSMS, across the customs frontier was complete at that point of time. Their storage at I.C.D. Dadri was only a facilitation arrangement to ensure further compliances of the provisions of the Customs Act. It was not determinative of the physical crossing of the goods across the customs frontier of the country. 21. Then, reference has been made to the permission to transport, obtained by the petitioner....
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....e manufactured goods liable to suffer Excise duty under the Act. Yet, it would not render the imported article HSMS unfit for human consumption. It did not make them fall outside the legislative competence of the State of U.P., to impose Excise duty under the Act. 26. In such circumstances, it must be presumed, the goods that were dispatched against the two disputed transactions from I.C.D. Dadri were of requisite strength i.e., 68% & 67.6% v/v, measuring 24,440 & 24,596 Bulk litres, respectively. However, upon the same being tested for strength, upon their arrival at Modi Nagar, they were found to be of strength 67% and 66.21% v/v. It represented excessive loss, beyond the permissible limit i.e. 0.5%. It also represented excess loss of quantity 1300.85 Bulk litres. It is for that purpose that the Rule provides for realisation of Consideration Fee/'Pratiphal Shulk', to ensure, no quantity of excisable goods is dealt with except in compliance with the regulatory law enacted by the State. Relying on the amended law providing for permissible loss @ of 0.5%, as approved by the Supreme Court in State of U.P. and Others Vs. Delhi Cloth Mills and another, (1991) 1 SCC 454, it has been ....
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....nder Section 52 of the Customs Act. Then, the phrase 'crossing the custom frontier of India' has been defined under Section 2(a)(b) of the CST Act. It means crossing the limits of the area of a customs station within which imported goods or exported goods are ordinarily kept, before clearance by a custom authority. In turn, 'customs area' has been defined under Section 2(11) of the Customs Act. It reads: "2(11). "customs area' means the area of a customs station [or a warehouse] and includes any area in which imported goods or export goods are ordinarily kept before clearance by customs authorities." 30. Heard learned counsel for the parties (over a long period of time, interspersed with adjournments). In face of the first issue raised being purely legal, and in absence of any dispute as to fact, the objection raised by the State - to availability of pleadings (in the writ petition) - to support the first ground of challenge raised, is not accepted. To deal with the first submission advanced by learned counsel for the petitioner, it is relevant to take note of certain provisions of the Act, namely, sub-Sections (3-a), (11), (13), (17), (19), (20) and....
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....s the State Government shall direct, may be imposed, either generally or for any specified local area, on any excisable article13 (a) imported in accordance with the provisions of Section 12 (1); or (b) exported in accordance with the provisions of Section 13; or (c) transported; or (d) manufactured, cultivated or collected under any licence granted under Section 17; or (e) manufactured in any distillery established, or any distillery or brewery licensed, under Section 18 : Provided as follows- (i) duty shall not be so imposed on any article which has been imported into [***]India and was liable on such importation to duty under the Indian Tariff Act, 1894, or the Sea Customs Act, 1887; (ii) [* * *]. Explanation. - (1) Duty may be imposed under this section at different rates according to the places to which any excisable article is to be removed for consumption, or according to the varying strength and quality of such article. [(2) The State Government shall, in imposing an Excise duty or a countervailing duty as aforesaid and in fixing its rate, be guided by the directive principles specifie....
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....at Gujarat or at land port-ICD Dadri, Gautam Buddh Nagar (inside the State of U.P.), would make no difference to the determination of that issue. It would have been relevant if the impost under challenge had been of Excise duty on clearance/receipt of HSMS, in that form and condition. Here, it may be noted, undisputedly, the petitioner manufactures foreign liquor from HSMS at its distillery at Modi Nagar, Ghaziabad, by making adequate dilutions to HSMS under a pre-defined process; it thus obtains foreign liquor of strength 42.8% v/v; bottles the same and clears those excisable goods against payment of Excise duty, inside the State of U.P. Therefore, it is not the case of the petitioner that foreign liquor manufactured from HSMS was not dutiable under the Act. In fact, its case is otherwise. 37. In view of the above, the frontal aspect of the first submission advanced by learned counsel for the petitioner, is found to be misconceived. In absence of any impost of Excise duty under the Act, on HSMS, that aspect of the submission advanced, is academic. Strictly, it does not arise in the facts of the present case. However, it's other aspect may be examined a little later. 38. Also....
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....(1) The [State may make rules for the purpose of Government] carrying out the provisions of this Act or other law for the time being in force relating to excise revenue : ... (2) In particular and without prejudice to the generality of the foregoing provision, the State Government may make rules- ... (d) regulating the import, export, transport or possession of any [intoxicant]" (emphasis supplied) 41. Under the Act, numerous Rules have been framed from time to time. Apparently, for the sake of convenience and ready reference, they have been compiled in a compendium, popularly known as the U.P. Excise Manual (hereinafter referred to as the 'Excise Manual'). That compendium has been arranged in Chapters, broken into Sections, further structured into Parts, with various individual Rule numbers mentioned as paragraphs of that compendium, numbered consecutively, in a single series. Paragraph no. 12 of the Excise Manual reads as below: "12. Foreign liquor. - Foreign Liquor means- (1) beer and spirit, wines and liquors, which have been imported into India and are intended for human consumption and were liable, on such im....
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.... limit is prescribed for the export, transport or possession of foreign liquor (other than denatured spirit) obtained from overseas. Note. - No duty-paid foreign liquor imported from foreign countries (other than denatured spirit) exceeding 6 quart bottles shall be imported in Uttar Pradesh in the local areas mentioned in the following Schedule except under a pass issued in accordance with paragraphs 609 to 610 infra. SCHEDULE (1) All Municipal areas, (2) all town areas, (3) all cantonment areas, (4) all notified areas, and (5) all railway stations. (2) A bona fide traveller coming into Uttar Pradesh may import for his own personal use, Indian-made foreign liquor not exceeding two quart bottles in all. Indian-made foreign liquor may be imported in larger quantities only in accordance with the rules hereinafter following. There is no quantitative limit for transport of Indian-made foreign liquor. (3) No denatured spirit in excess of limit of retail sale shall be imported, exported or transported except under a pass as provided for in Sections 15 and 16 of the Act. 46. Part (A-1) of Chapter VIII, Section XXXVIII of the Excise Manual pertains ....
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....sented to the Collector of the district of import. The Collector shall issue a permit as laid down in sub-rule (d) only when the treasury challan evidencing payment of the fee is produced. (c) The importer shall also execute (unless a general bond previously executed by him still in force) either a general or a special bond in the prescribed form in favour of the Collector of the district of import for the payment of duty leviable under Section 28 on the actual import and on the excess loss in transit according to the rule in force in the exporting State or Union Territory. (d) The Collector shall, unless there is any reason to the contrary, prepare a permit in triplicate in Form F.L. 22 sanctioning the import under bond. The permit shall contain all the particulars specified in sub-clause (a) and shall clearly specify that a bond for payment of duty has been executed in the district of import. One copy of the permit shall be made over to the importer, the second copy shall be forwarded to the Chief Revenue Authority of the district of export and the third shall be retained by the Collector for record and verification of the consignment on arrival. The permit shal....
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....an be no dispute, HSMS at 68% and 67.6% strength v/v did not render itself alcoholic liquor unfit for human consumption. At present, that principle or test maybe available, only with respect to alcoholic liquors of much higher strength i.e., above 80-85%. This observation is being recorded, on the strength of the undisputed individual facts of this case, seen in the light of the decision of the Supreme Court in State of U.P. & Ors. Vs. Modi Distilleries & Ors. (supra), wherein while dealing with Group-B cases (involving cases of high strength malt spirit of 80-85% strength), it was observed as below:- "10. What the State seeks to levy excise duty upon in the Group 'B' cases is the wastage of liquor after distillation, but before dilution; and, in the Group 'D' cases, the pipeline loss of liquor during the process of manufacture, before dilution. It is clear, therefore, that what the State seeks to levy excise duty upon is not alcoholic liquor for human consumption but the raw material or input still in process of being rendered fit for consumption by human beings. The State is not empowered to levy excise duty on the raw material or input that is in the process of being ma....
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....on created under Proviso (i) to Section 28(1) of the Act. 53. However, that does not offer any legal mystery or difficulty as to operation and/or order of primacy of enacted laws, noticed above. In this situation, two mutually independent consequences arose, under two different laws, neither in conflict with the other. Each law was enacted by the competent legislature for its own independent and (mutually) exclusive purpose. The Customs Act sought to levy Customs duty on the import of HSMS while the Act, amongst others, sought to regulate transportation of the commodity/article thus cleared for home consumption (under the Customs Act), inside the State of U.P. Therefore, there is no conflict between the two laws. 54. For the imposition of tax or Customs duty liability, on imported HSMS, it must be accepted and recognised, the goods were imported across the customs frontiers of the country at I.C.D. Dadri, in Gautam Budh Nagar. Therefore, no amount of Excise duty may have been imposed under the Act, on those goods till they remained HSMS. Yet, by way of a regulatory measure, the State legislature could bind the importer/petitioner to account for the entire quantity of HSMS thu....
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....at this cannot be done." 15. The next question is whether the levy is in the nature of tax or excise duty. If it is a case of excise duty on potable liquor produced by use of imported rectified spirit, the State has jurisdiction to legislate in respect of duty on the production or manufacture of such goods produced or manufactured within the State. In the present case, we find merits in the submissions of the appellant State that the impost is neither in the nature of a tax nor excise duty but it is towards the charges by whatever name, for regulating the production of potable liquor to preserve public health and morality including for parting with its rights or privileges regarding manufacture, supply or sale of potable liquor or intoxicating liquor and to regulate the use of imported rectified spirit for production and sale of potable liquor. In such a case, the State need bear no quid pro quo to the services rendered to the licensee for production of foreign liquor (IMFL). 16. The fact that the manufacturer-respondent has already obtained requisite licences for import of rectified spirit and production of foreign liquor (IMFL) on payment of fixed rates does not....
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....have been contemplated by the legislature. 58. The provisions of Sections 15 and 16 of the Act read with Paragraph Nos. 605 to 613 of the Excise Manual are part of the regulatory laws. The clear intent of those provisions is to ensure, no quantity of foreign liquor, suffers excessive loss, amongst others during its transportation inside the State of Uttar Pradesh, as may result in a corresponding revenue loss. It is clearly a provision in the interest of revenue to prevent unscrupulous importers from drawing excessive profits at the cost of corresponding undue loss of revenue to the State-by arranging the import/export/transport transaction/s in a manner whereby excessive quantities of foreign liquor may be claimed lost, though the same may have been unscrupulously removed during their transportation, to obtain liquor, either of same strength or lesser strength. In the present case, as recorded in the show cause notices, the goods HSMS were lost both in quantity and strength. 59. Undisputedly, under Section 3 of the Act, where the context otherwise requires, the statutory definition of any word or phrase, may be departed. There is no exception to doubt the same. In Dhandhania....
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....icable. 61. Again, as a fact, reference may be made to the application made by the petitioner for grant of Form FL-22. Copies of letters dated 02.08.2018 and 31.08.2018 issued by the petitioner to import 24,400 Bulk litres of HSMS and 24,346 Bulk litres of HSMS respectively, have been annexed as Annexure no.1 & 1A to the Supplementary Counter Affidavit, filed by the State. For ready reference, contents of letter dated 02.08.2018 are quoted hereinbelow: "Ref. CE/AL/ 02/08/18 To, The Excise Commissioner, UP Excise ALLAHABAD, Uttar Pradesh Subject: Import/Lifting of 24400.00 BL(16608.5 AL with 68.0% v/v alcoholic strength) Imported Malt Scotch from L.C.D. Dadri, Dist. Gautam Budh Nagar (U.P). Dear Sir, We wish to submit that we want to Import/purchase 24400.0 B.L. (16608.5 AL with 68.0% v/v alcoholic strength) of 3 years old Vatted Malt Scotch from M/s William Grant & Sons Distillers Ltd., Giravan Distillery, Grangestone Industrial Estate, Girvan, Scotland via invoice no.3003501 dt. 06/06/2018 for the development of IMFL products in our distillery. The 24400.00 BL Malt Scotch will come to India in tank....
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.... 20/08/2018 SEAL OF THE OFFICE OF ISSUE -sd/- 21/08118 DISTRICT EXCISE OFFICER GHAZIABAD DISTRICT, GHAZIABAD (UP)" 63. Thus, in view of the scheme of Sections 15 & 16 of the Act, the petitioner sought permission to transport quantities of HSMS cleared in its favour, by the Customs authorities at I.C.D. at Dadri, Gautam Budh Nagar, for 'transportation' to its distillery, at Modi Nagar, Ghaziabad. It was described by the petitioner as a transaction of import, from I.C.D. Dadri. Yet, the nature of that transaction involved inter-play of the laws enacted by the State legislature i.e. the Act read with the Rules framed thereunder and the laws enacted by the Parliament, namely, the Customs Act and the Rules framed thereunder. 64. There is no conflict between the Customs laws enacted by the Parliament and the regulatory laws enacted by the State legislature. Under Chapter VIII of the Customs Act, the procedure is prescribed to obtain clearance of goods, for import and export. Section 45 of the Customs Act places restriction on the custody and removal of imported goods. Thus, goods imported from outside the country are ....
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....sed goods may be cleared from the warehouse for home consumption, if- (a) a bill of entry for home consumption in respect of such goods has been presented in the prescribed form; (b) the import duty, interest, fine and penalties payable in respect of such goods have been paid; and] (c) an order for clearance of such goods for home consumption has been made by the proper officer;" 66. In the context of the above-described Custom laws, Circular no. 50/2020 dated 05.11.2020 (relied upon by learned counsel for the petitioner), was issued. Contents of paragraph nos. 2, 2.1, 2.1.1, 2.1.2, 2.4, 2.4.1, 2.4.2, 2.4.3 and 2.4.4 are quoted below: " 2. Distinction between ICD, CFS and AFS 2.1 Inland Container Depot (ICD) : 2.1.1. An off seaport (or port) facility. having such fixed installations or otherwise, equipment, machinery etc. providing services for handling / clearance of laden import, export containers for home use, warehousing, temporary admissions, re-export etc under customs control and with storage facility for customs bonded or non-bonded cargo. 2.1.2. An ICD is a "self-contained Customs station" like a port or air....
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....al CFSS attached to it within the jurisdiction of the Commissioner of Customs just as in the case of a port. 2.3. Air Freight Station (AFS) 2.3.1. An off-airport common user facility equipped with fixed installations of minimum crement and offering services for handling and temporary storage of import and export cargo etc. 2.3.2. While CFS handles maritime cargo, an AFS is meant to handle air cargo. 2.4. Important centers of activity relating to ICDs/CFSs/AFSS 2.4.1 Pail Siding (in case of a rail-based terminal): The place where container trains are ved, dispatched and handled in a terminal. Similarly, the containers are loaded on and unloaded from rail wagons at the siding through overhead cranes and / or other the equipment. 2.4.2 Container Yard: Container yard occupies the largest area in the ICD/CFS. It is acting area where the export containers are aggregated prior to dispatch to port, pt containers are stored till Customs clearance and where empty containers await movement. Likewise, some stacking areas are earmarked for keeping special ners such as refrigerated, hazardous, overweight/over-length etc. 2.4.3. Wareh....
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....itioner, may not be faulted. 70. The import of HSMS from Scotland, in United Kingdom was not complete till the goods were cleared for home consumption, at I.C.D., Dadri. There is no fact allegation made by the petitioner of any loss of strength or volume suffered before the goods reached the I.C.D. Dadri. Therefore, the excessive loss - of strength and volume (of HSMS), occurred during the transportation of those goods, from the bonded warehouse at I.C.D., Dadri, to the petitioner's distillery at Modi Nagar, Ghaziabad, after their clearance for human consumption. 71. Examined in the context of discussion made above, the geographical place where the goods HSMS commenced their journey (upon being cleared from home consumption) remained inside the State of Uttar Pradesh, i.e., at Dadri, in Gautam Budh Nagar. Yet, HSMS had not been produced inside the State of Uttar Pradesh. In fact, they were imported into the country, at the I.C.D., Dadri, in Gautam Budh Nagar. Therefore, those goods became available for home consumption, under the umbrella of local regulatory laws of the State of Uttar Pradesh, only. Keeping these facts in mind, for the purpose of levy of Consideration fee/'Pr....
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....r and assigns) of the other part; Whereas under the rules of the Government of Uttar Pradesh in the Excise Department the distiller is/distillers are permitted from time to time to transport/export spirits from his/their distillery at. ...to all or any of the bonded warehouses mentioned in the passes covering such transport/export without previous payment of duty on the distiller/ distillers executing an indemnity bond on the terms and conditions hereinafter mentioned; Now this Bond witnesses and the distiller/distillers hereby convents/convent with the Governor as follows: 1. That the distiller/distillers shall not at any one time to so transport/export any quantity of spirits the duty on which at the rate prescribed therefor at the time or the aggregate of such duty and the duty at the aforesaid rate on any quantity previously transported/exported and not yet delivered at destination shall exceed the sum of Rupees Provided that any allowance sanctioned for dryage and wastage and any quantity not delivered at destination for which duty has been paid under clause (3) hereinafter following shall not be included in the calculation of the quantity not delive....
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....#39; in question was only an agreement. 74. Under the Act, 'bond' has not been defined. However, whether we treat the bond (that may have been issued in the present case), to be a bond simplicitor or an agreement, once issued, it would bind the issuer to account for the entire quantities of the Excisable article (as they existed at the beginning of their journey), at the end of that journey. For that reason also, exact terms of the bond apart, the nature of liability to pay Consideration fee/'Pratiphal Shulk' against excess loss of HSMS may remain enforceable, by way of a pure contractual liability. 75. For reasons noted above, it would not be right to say - the Act and the Excise Manual create levy of Consideration Fee/'Pratiphal Shulk' only on dispatches made from the distillery and not to the distillery. All transportation of liquor within the State, is covered within the regulatory sweep of Sections 15 & 16 of the Act. The petitioner applied and the respondents granted Pass to the petitioner (to transport HSMS from I.C.D. Dadri, in Gautam Budh Nagar to petitioner's distillery at Modi Nagar, Ghaziabad), on Form FL-22, against bond. That procedure was not co....
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