JUDGMENT

RANGANATHAN, J.:— These three appeals under S. 130-E(b) of the Customs Act, 1962 raise the same issue. They are therefore disposed of by a common order.

2. The respondent - M/s. K. Mohan & Co. - imported, from Japan, "metallised polyester films" under an import licence dated 14-6-1978. The goods were admittedly in the shape of film rolls several metres long. They were cleared on payment of customs duty leviable under the Customs Act, 1962 (CA) as well as the additional duty of customs (or countervailing duty) leviable under S. 3 of the Customs Tariff Act, 1975 (CTA). Subsequently, the respondent firm made three applications for the refund of the amount of the additional duty of customs paid by it. The claim for refund was based on the terms of a notification of exemption issued under S. 25(l) of the CA. Under notification No. 228/76 dated 2-8-1976, an exemption from the customs duty payable under S. 3 of the CTA was granted in respect of "articles made of plastics, all sorts, but excluding those specified in the table annexed hereto and falling within Chapter 39 of the First Schedule to the Customs Tariff Act, 1975 (51 of 1975)". The annexed table excepted the following ite