(1) THE dispute in these two appeals lies in a narrow compass. The appellants manufacture rigid plastic laminates. For this purpose, they procure paper, cotton fabrics and glass fabrics as raw materials and treat them with synthetic resin. This results in the manufacture of treated paper, treated cotton fabric and treated glass fabric. Layers of such treated paper, cotton fabric and glass sheets are compressed under heat to form rigid plastic laminates. The contention of the Revenue is that the intermediary product, namely, treated paper and treated cotton fabric (we are not concerned with treated glass fabrics) is liable to duty under Items 17(2 and 19(III) respectively of the central Excise Tariff as in operation at the relevant date. Since these treated paper and cotton fabric sheets were consumed captively for the manufacture of rigid plastic laminates, admittedly, no duty was paid on the intermediary product under the aforesaid two tariff items, but duty was paid on the final product. The contention of the Revenue is that since the appellants had failed to pay the duty on the intermediary product under the aforesaid two entries, the Revenue is entitled to recover the s