JUDGMENT

RANGANATHAN, J. :—These two appeals by Thermax (Pvt.) Ltd. (hereinafter referred to as the assesses) raise a question of interpretation of two similar Notifications issued under S. 8 of the Central Excises and Salt Act, 1944 (the Act, for short).

2. The assessee imported goods described as "Sanyo Single Effect Chiller" from Japan for the purpose of using the same for refrigeration/ air-conditioning of the factories of Indian Rayon Corporation at Veraval and Nirlon Synthetics Fibre and Chemicals Ltd. It paid the customs duty leviable thereon at the appropriate rate under the relevant entry of the customs tariff but claimed exemption from the additional duty of customs leviable under S. 3(l) of the Customs Tariff Act, 1975 (C.T. Act, in short). The relevant portion of the said section reads thus :

"3.(1) Any article which is imported into India shall, in addition, be liable to a duty (hereafter in this section referred to as the additional duty) equal to the excise duty for the time being leviable on a like article if produced or manufactured in India and if such excise duty on a like article is leviable at any percentage of its value, the additional duty to which the imported