Judgment

RANGANATHAN, J.:- All these appeals involve a common question as to whether the goods exported by the appellants are liable to export duty. There are 67 appeals which relate to various batches of exports made by the appellants during the period from 4-3-76 to 14-2-1982. They will be disposed of by this common order.

2. The goods exported by the appellants are blanched, roasted and salted peanuts packed in vacuum containers. The appellants purchase groundnuts without shell in raw form from various parts of Saurashtra in the State of Gujarat. Thereafter, they are sorted out into different sized - small, medium and big. The medium and small sized are separated. Dust and husk are cleaned out and other foreign material removed. The commodity then goes to a dry roaster where it is roasted at a temperature of 1500C. This results in reduction of the moisture and destruction of enzymes to a considerable extent. It is also stated that by this process any fungus or aflatoxin is removed. After dry roasting, the product is cooled down with the aid of a blower so that the skin of the groundnuts become loose and the groundnut contracts. Thereafter, it goes through automatic blanching machi