Judgment

RAY, C. J.:- These appeals are by certificate from the judgment D/- 18 April, 1969 of the High Court of Patna.

2. The High Court quashed the orders of the Revenue Authorities dated 7 July, 1967.

3. The appellants claimed before the Revenue Authority exemption from the payment of duty in respect of duty-paid pig iron which was used in the making of steel ingots.

4. The respondents manufactures iron and steel products. The respondent manufactures ingot moulds and bottom stools from big iron for use in steel melting shops. The respondent pays Central excise duty on such ingot moulds and bottom stools in accordance with the provisions contained in Section 3 of the Central Excises and Salt Act, 1944 hereinafter referred to as the Act.

5. Section 3 of the Act is the charging section. Section 3 states that there shall be levied and collected in such manner as may be prescribed duties of excise on all excisable goods other than salt which are produced or manufactured at the rates set forth in the First Schedule.

6. Prior to the Finance Act, 1964 Items Nos. 25 and 26 in the First Schedule to the Act mentioned pig iron and steel ingot respectively as the description of goods subject to ex