JUDGMENT

R.C. Lahoti, J.-The respondents are engaged in the manufacture of insecticides, fungicides, weedicides and pesticides falling under Tariff sub-heading 3808.10 and excisable thereunder. During the process of manufacturing Mercuric Acetate (MA), Para Chloro Phenyl Valeric Acid (PCA), and Chloro Synthemic Acid Chloride (CSA Chloride) came into existence as intermediate products. The Collector of Central Excise passed orders of adjudication holding the abovesaid three intermediate products liable to payment of excise duty. The respondents preferred appeals before the Collector (Appeals) who has allowed the appeals exonerating the said three intermediate products from levy of excise duty. The appeals preferred by the Revenue against the order of Collector (Appeals) have been dismissed by a common order by the CEGAT. The aggrieved Revenue has come up by filing these appeals to this Court.

2. It is well settled by a series of pronouncements of this Court from Bhor Industries Ltd. v. Collector of Central Excise1 to Union of India v. Delhi Cloth and General Mills Co. Ltd.2 that excise is a duty on goods as specified in the Schedule. The taxable event in the case of excise duty is the