JUDGMENT

S. P BHARUCHA, J. - WP (C) No. 1583 of 1986 The writ petitioners imported stainless steel strips. The stainless steel strips arrived at Bombay on 6-9-1976. They were cleared for home consumption on 16-9- 1976 and 30-9-1976. They were cleared giving them the benefit of exemption from customs duty as provided by Exemption Notification No. 256-Cus/76 issued under the provisions of Section 25(1) of the Customs Act, 1962. On 10-1-1977 and 11-1-1977, the writ petitioners received notices to show cause why they should not be charged duty at the unexempted rate on the ground that the width of the said strips was in excess of that permitted by the said exemption notification.

2. On 24-2-1977, Exemption Notification No. 27/77 was issued giving an exemption from customs duty to stainless steel strips of a width exceeding 127 mm and of a thickness of 3.175 mm and above.

3. On 25-3-1977, the petitioners wrote to the Central Board of Excise and Customs with reference to a notification that had specially been issued a in favour of MIs Ahmedabad Advance Mills Ltd., Navsari, Bombay, who had imported identical stainless steel strips at about the same time as the petitioners. The petitioners