BPCL To Appeal Rs 18,166.5 mn Excise Demand Order

26 Feb 2026 CW Team

Bharat Petroleum Corporation Limited (BPCL) has received an excise duty demand order from the Commissioner of Central Tax and Central Excise, Kochi, for an amount of Rs 18,166.5 million (mn) including interest. The company said the order was passed on 21 February 2026 and relates to transactions undertaken during the period September 2004 to May 2010. The demand follows valuation disputes linked to operations at the Kochi refinery. BPCL indicated it will challenge the order before the appellate authority.

The total demand comprises excise duty of Rs 4,769.4 million (mn), interest of Rs 13,397 million (mn) and a penalty of Rs 95,000. The issue stems from 19 show cause notices issued by the central excise department concerning valuation under the Central Excise Valuation Rules, 2000 in respect of Kochi Refineries Limited (KRL), which subsequently merged with BPCL. The notices relate to the valuation methodology applied to clearances over the relevant period.

According to the adjudicating authority, BPCL and KRL were treated as related persons under excise law and the transaction value adopted by the company was disallowed. The department applied valuation on the basis of the highest price for the entire fortnight across all clearances rather than the pricing methodology used by BPCL. After the merger, BPCL had adopted valuation based on the highest quantity depot price but the excise authority rejected that approach in adjudication.

The company said it will analyse the order and file an appeal before the Hon'ble Customs, Excise and Service Tax Appellate Tribunal, commonly known as CESTAT. It did not state whether any provision had been made in its books for the demand, nor did it indicate a timeline for lodging the appeal. The matter is expected to be decided through the appellate process and any final liability will depend on the tribunal outcome and further legal proceedings.

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