ORDER

1. The respondents imported three consignments consisting of 532 coils of Tin Imported Black Plate in regard to which the bills of entries were presented on 19, 28 and 29-12-1983 on a prior entry basis and the goods were assessed free of duty in terms of the Notification No. 243-Customs dated 13-11-1981 as amended by Notifications Nos. 215-Customs and 126-Customs dated 29-9-1982 and 13-5-1983 respectively. The benefit of the exemption was available until 31-12- 1983. All the three vessels travelled through Bombay and Madras to Calcutta. The goods carried in the three vessels were cleared on 10, 11, 12 and 24-1-1984. Under Section 15 read with Section 46 of the Customs Act, 1962 the relevant date for determination of the rate of duty in the case of goods entered for home consumption, is the date on which the bill of entry in respect of such goods is presented, provided that if it has been presented before the date of actual entry it shall a be deemed to have been presented on the date of such actual entry. The bills were presented on prior entry basis on three different dates in December 1983 as mentioned above but since the three vessels entered the Port of Calcutta on the re