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While the levy in our country has the status of a constitutional concept, the point of

collection is located where the statute declares it will be. The measure adopted cannot be
identified with the nature of the tax. The measure employed for assessing a tax must not
be confused with the nature of the tax. While the levy of a tax is defined by its nature, the
measure of the tax may be assessed by its own standard. While the measure of the levy
may indicate the nature of the tax, it does not necessarily determine it. Hence, the
Legislature, while enacting a measure to serve as a standard for assessing the levy need
not contour it along the lines which spell out the character of the levy itself.

(c) The contention that the duty of excise can be and must be levied only on
manufacturing cost and manufacturing profit is unacceptable. "In both the old Section
4 and the new Section 4, the price charged by the manufacturer on a sale by him
represents the measure. Price and sale are related concept and price has a definite
connotation. The 'value' of the excisable article has to be computed with reference to the
price charged by the manufacturer, the computation being made in accordance with the
terms of Section 4."

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