Judgment

S.B. Majmudar, J.-This appeal under Section 35 (L) of the Central Excise & Salt Act, 1944 (hereinafter referred to as the Act ) is brought by the appellant-assessee on being aggrieved by the decision rendered by the Customs, Excise and Gold (Control) Appellate Tribunal (CEGAT for short) dismissing the assessee s appeal against the order in original passed by the Collector of Central Excise, Bolpur.

2. A few relevant facts leading to this appeal deserve to be noted at the outset. The appellant, Steel Authority of India Ltd. is a wholly owned Government of India Company. The appellant-company has several steel plants and Durgapur Steel Plant (DSP), situated at Durgapur in West Bengal, is one of the integrated steel plants of the appellant-company. DSP manufactures pig iron, steel ingots and several steel products. These products of DSP prior to 1983 were classified under the erstwhile Tariff Items 25, 26 and 26AA. The appellant-company has been paying excise duty on these items under reference following the principles of "later the better". The appropriate Central Excise Duty was determined and paid on iron and steel products, when cleared. The evidence led by the appellant e