JUDGMENT

PARIPOORNAN, J.:- This is an appeal filed by an assessee against the order passed by the Customs, Excise and Gold (Control) Appellate Tribunal, New Delhi, dated 11-11-1983, under Section 35-L(b) of the Central Excises and Salt Act, 1944, (hereinafter referred to as the Act). The respondents represent the revenue. The short question that arises for consideration in this appeal is, whether a duty of excise was validly levied on "PVC compound" produced by the appellant from out of the duty paid PVC resin. The levy of duty relates to the period from 18-6-1977 to 28-6-1977. The Assistant Collector of Central Excise, by his order dated 28-7-1978, held that the PVC compound in the form of granules produced by the assessee were eligible to duty for the period from 18-6-1977 to 28-6-1977, under Rule 10 of Central Excise Rules, 1944. He allowed set off in respect of the duty paid on PVC resins and used in the production of PVC compound. In appeal, the Appellate Collector of Central Excise, by his order dated 28-8-1979, held that the appellant manufactured PVC compound (granule) for insulation of their products, electric wires and cables, and the resultant PVC compound is a new produ