Judgment

KANIA, J.:- These appeals arise from a judgment of the Customs, Excise and Gold (Control) Appellate Tribunal (South Regional Bench) at Madras.

2. The facts necessary for the disposal of these appeals are as follows:

The appellant is a manufacturer of motor vehicle parts falling under Item 34-A of the Central Excise Tariff and components for I.C. Engines falling under Item 68 of the said Tariff. The period with which we are concerned in these appeals is the period from Oct. 1, 1975 to July 21, 1984. The marketing pattern of the appellant was that they sold goods in the wholesale to O.E. manufacturers, Transport Undertakings and Government Bodies. The requirements of the replacement market were met by the appellant by sale in the wholesale to other persons who were designated by the appellant as distributors/ primary wholesale buyers on the basis of agreements with such distributors. The amendment to Section 4 of the Central Excises and Salt Act, 1944 (hereinafter referred to as "the Central Excises Act) came into force from October 1, 1975 and, as from that date,, the Department took the view that sales by the appellant to its distributors would be considered as sales to relat