Judgment

V. RAMASWAMI, J.:- The appellants are a public limited company having a factory at Faridabad and engaged in manufacturing air-conditioning and refrigeration equipment of various kinds and descriptions. They are holding a L-4 Licence to manufacture goods falling under Tariff Item No. 29A of the Central Excise Tariff. As per classification lists submitted from time to time under R. 173B of the Central Excise Rules, 1944, the company had declared in Form I that they are engaged in the manufacture of goods falling under sub-items (2) and (3) of Tariff Item. No. 29A. Against gate passes Nos. 111, 112 and 113 dated January 21, 1970 and gate pass No. 116 dated January 22,1970 the appellants had cleared from the factory cooling coils, condensors and compressors and supplied the same for putting up a cold storage plant to one M/s. Ravi Cold Storage, Ahmedabad. These parts were manufactured by the appellants in their factory at Faridabad and were cleared by them against the abovementioned gate passes after payment of a duty of Rs. 13,547.20 p. Against gate passes Nos, 95, 96, 97 and 98 dated January 21, 1969 the appellants had cleared from the factory various parts of refrigerating a