JUDGMENT

RANGANATHAN, J.:— The appellant, M/s. Auto Tractors Limited, is a company manufacturing tractors. For purposes of manufacture, the company imports certain parts and components from abroad.

2. There are two notifications of the Government of India granting certain concessions from the levy of customs duty which are applicable to such goods as have been imported by the appellant. The first of these, namely, Notification No. 200/79 dated 28-9-1979 (as amended from time to time) exempts components "required for the manufacture of heavy commercial motor vehicles........or of tractors" from so much of the customs duty as is in excess of 25 per cent ad valorem and the whole of the additional duty leviable thereon. The grant of the concession subject to the fulfilment of certain conditions specified in the notification. The second notification was notification No. 179/80 dated 4-9-1980 (as amended from time to time). This notification confers an exemption in respect of parts of articles falling under specific headings in the First Schedule to the Customs Tariff Act, 1975. These admittedly included parts required for the purposes of the initial setting up or for the assembly or manu