JUDGMENT

S.P. BHARUCHA, J.

(1) THE appellant manufactures audio equipment at a factory at Pune. It was served with a show-cause-cum-demand notice on 3/12/1986, by the Collector of central Excise alleging that the assessable value of the goods manufactured by it during the period 1983 to 1986 had not been correctly determined inasmuch as the appellant had claimed inadmissible deductions from the price realised from its dealers on account of, amongst others, "normal trade discount although a substantial part thereof represented advertisement expenses and expenses on after-sales service which were includible in the assessable value. The demand in this behalf was upheld as representing 2% of the trade discount. The tribunal was moved in appeal. It noted the terms of agreements entered into between the appellant and its dealers and dismissed the appeal. In regard to the service rendered by the dealers during the guarantee period, the tribunal observed that there was nothing on record to show that the expenses incurred by the dealers on this account were reimbursed by the appellant and, upon this basis it said, "Obviously, the dealer was to meet these expenses out of the discount o