Judgment

Kirpal, J.-These appeals involve for decision the question whether notional interest on the interest free security deposit received should be considered for the purpose of arriving at the assessable value under the Excise Act by including interest at the rate of 12% per cent per annum on such security deposits.

2. VST Industries Ltd. (appellant in CA No. 2524/92) is a company carrying on business of manufacture and sale of cigarettes which was assessable to duty under the erstwhile Item No. 4 of the First Schedule to the Central Excise and Salt Act, 1944. The other two appellants, namely, Venus Tobacco Company Pvt. Ltd. (appellant in CA No. 2523/92) and Hyderabad Deccan Cigarette Factory Ltd. (appellant in CA No. 2611/92) are also cigarette manufacturers and use their plant and machinery to manufacture citgarettes for and on behalf of VST Indus­tries Ltd. (hereinafter referred to as “VST”). The question involved in these appeals, therefore, relates to the fixation of the assessable value of the cigarettes manufactured and sold under the brand name owned by VST.

3. The undisputed facts are that the cigarettes manufactured by the appellants are sold in wholesale, ex-factory, at