JUDGMENT

S. C. AGRAWAL, J.:—This appeal has been filed under Section 130 E(b) of the Customs Act, 1962 (hereinafter referred to as the Act) against the order dated July 29, 1986 gassed by the Customs, Excise & Gold (Control) Appellate Tribunal (hereinafter referred to as the Appellate Tribunal) whereby the Appellate Tribunal dismissed the appeal of the appellant against the order dated February 24, 1983 passed by the Collector of Customs & Central Excise, -Cochin (hereinafter referred to as the Collector).

2. M/s. Jacsons Thevara, the appellant herein, is a partnership firm. It was originally constituted on January 1, 1973, with two partners, Jacob Punnoose and K.O.Thomas.It was registered as a Small Scale Industrial Unit with the Department of Industries & Commerce of the Government of Kerala, and was manufacturing wooden furniture and flush doors. The firm was reconstituted on January 1, 1974, and two minors, Thomman Jacob and Phili Jacob, were admitted to the benefits of the partnership. The reconstituted firm started manufacturing decorative Veneers of 3 mm thick by manual sawing operations. In July 1978, the appellant decided to diversify its business by manufacturing sophisti