JUDGMENT

B.P. Singh, J.-In this appeal the appellant has impugned the final order of the Customs, Excise and Gold (Control) Appellate Tribunal (for short CEGAT ) dated 28.12.1995 dismissing its appeal against the order of the Collector of Central Excise, Raipur, confirming the demand of duty on Hydraulic Mudguns and Tap Hole Drilling Machines, and imposing a penalty of Rs. 8 lakhs for suppressing the fact of such manufacture and removal of excisable goods from the Department of Central Excise, failure to obtain Central Excise Licence and its failure to maintain statutory records and to file the required returns.

2. The facts of the case are not in dispute. The appellant-Company pursuant to the acceptance of its tender, entered into an agreement with M/s SAIL, Bhilai Steel Plant for design, supply, supervision of erection and commissioning of four sets of Hydraulic Mudguns and Tap Hole Drilling Machines required for blast furnace Nos. 4 and 6 of the Bhilai Steel Plant. For this purpose, it imported several components and also manufactured some of the components at their factory in Marai Malai Nagar, Chennai. These components were transported to the site at Bhilai where the manufactur