JUDGMENT

Kirpal, J.—These appeals have been filed against the common order dated 15th November, 1999 of the Customs, Excise and Gold (Control) Appellate Tribunal which, while confirming the order of the Commissioner of Customs held that drawings, designs etc. relating to machinery or industrial technology were goods which were leviable to duty of customs on their transaction value at the time of their import.

2. As principal arguments on behalf of the appellants were addressed in the case of M/s. Hotel Leela Ventures Limited by Mr. Ashok H. Desai, learned senior counsel, for the sake of convenience we will refer to the relevant facts in that case in greater detail.

3. Leela Ventures are engaged in the business of setting up, operating and maintaining Hotels and Resorts. For designing the Hotels and Resorts, it engaged a foreign company M/s. Wimberly Allison Tong & Goo, USA (“WAT” for short) for providing architectural services including design development drawings. Leela Ventures had entered into four agreements with the said foreign company in respect of four different ventures in India. Apart from preparing the designs and drawings the scope of work under the said agreements in