JUDGMENT

BHARUCHA, J. :—These appeals may be disposed of by a common judgment inasmuch as the Customs. Excise and Gold (Control) Appellate Tribunal allowed the appeal in the case of M/s. Steel Strips Ltd. (Civil Appeal No. 438 of 1989 before us) following its judgment in the case of M/s. Atma Steel Pvt. Ltd. (Civil Appeal No. 3524 of 1986 before us).

2. The assesses make cold rolled steel strips from hot rolled steel strips. The applicable entry of the Central Excise Tariff is Tarrif Item No. 26AA, which deals with "Iron or steel products the following, namely :

xxx xxx xxx

(iii) Flats, skelp and strips

xxx xxx xxx"

For the relevant period, being March 1982 to February 1986, an Exemption Notification was in operation in regard to steel strips, being notification No.55/80 dated 13th May, 1980, as amended, issued under rule 8 of the Central Excise Rules, 1944. It exempted galvanised strips and other than galvanised strips from so much of the basic excise duty leviable thereon as was in excess of Rs. 850/- per metric tonne and Rs.350/- per metric tonne respectively. It then referred to "other cold-rolled strips" and "other hot-rolled strips" and exempted them from so much of the basic exc