Judgment

S. Saghir Ahmad, J.-In this appeal in which four sets of court fees have been paid, the correctness of the common judgment passed by the Customs Excise and Gold (Control) Appellate Tribunal (for short, ‘the Tribunal’) in the three appeals filed by the Revenue and one filed by the present appellants, is questioned.

2. The appellants manufacture high pressure Boilers, Process Heat Equipment etc. as per requirements of the customers. The manufacturing process includes pre and post manufacturing steps. Since Boiler has to be manufactured according to the requirements of the customers, the pre-manufac­turing process includes the inspection of site where the Boiler is to be installed and the making of its drawings and designs etc. for which the appellants charge and had all along charged sepa­rately from its customers. The post-manufacturing steps include the installation, erection and commissioning of the Boiler at the site for which also the appellants have charged specific amounts from their customers under separate invoices.

3. Three separate show cause notices dated December 26, 1983; February 3, 1984 and July 30, 1984 were issued to the appellants in which it was pointed ou