Dismissing the appeal of the revenue the Court held that assessee’s liability to pay excise duty on goods manufactured arises only at time of removal of same from its premises, be it distillery, or a warehouse or any other place of storage and not at any time earlier and till date of clearance of goods, assessee cannot be said to have incurred excise duty liability. Accordingly in respect of excisable goods manufactured and lying in stock, excise duty element is not to be included in valuation of closing stock. (AY. 1999-2000)