( 1 ) THE only question that falls for consideration in these appeals is whether the appellants can claim the benefit of concessional rate of customs duty under Tariff Head 84. 66 in the First Schedule to the Customs Tariff Act, 1975.

( 2 ) THE facts, in brief, are as follows: The appellants entered into a contract on 17/12/1982 with M/s Kohli Graphic Systems, the Indian agent of the German Supplier, M/s Dr Ing Rudolf Hell GMBH, for the import of Chromograph C-399 colour scanner. Under the terms of the contract the equipment was to be initially imported on behalf of the supplier for display in Pamex Exhibition to be held at New Delhi in January 1983 and after closure of the exhibition it was to be cleared for delivery to the appellants after completion of customs formalities. The equipment was imported by M/s Kohli Graphic Systems on behalf of thesupplier and the Bill of Entry in respect of the same was submitted by them before the Customs authorities on 15/1/1983. The goods were cleared without paying any customs duty on the basis of Notification No. 116/79 dated 1/6/1979 issued under Section 25 (1 of the Customs Act, 1962 wherein goods imported into India in connection with any fair, exhibition, demonstration, seminar, congress and conference are exempted from the whole of the duty of customs leviable thereon under the First Schedule to the Customs Tariff Act, 1975 (51 of 1975 and the additional duty of customs leviable thereon under Section 3 of the said Customs Tariff Act. One of the conditions imposed under the said notification was that the importer had to execute a bond to the satisfaction of the Assistant Collector of Customs to re-export the goods within the period of six months from the date of official closure of such fair, exhibition, demonstration, seminar, congress and conference or as the case may be within such extended period as the Assistant Collector of Customs may allow and in the event of failure to re-export as aforesaid, to pay the duty which would have been levied thereon but for the exemption contained in the notification. In accordance with the said requirement, the German supplier furnished the necessary bond undertaking to re-export the goods after the exhibition. After the exhibition was over, as per the terms of the said bond, the goods were deposited on 10/2/1983 in the Northern Railway Godown at the Exhibition Ground at New Delhi, which was under the control and custody of the Customs authorities. On 6/6/1983 the contract entered into by the appellants with M/s Kohli Graphic Systems was registered under the Project Import (Registration of Contract) Regulations, 1975 with the Assistant Collector of Customs (Contract Section), Customs House, Bombay in accordance with the provisions of the proviso to Tariff Head 84. 66 of the Customs Tariff Act in order to avail the benefit of concessional rate of customs duty. Thereafter, on 20/6/1983, the appellants filed another Bill of Entry for clearance of the goods which were lying in deposit with the Northern Railway Godown under Tariff Head 84. 66. The Assistant Collector of Customs, by his letter dated 23/6/1983, informed the appellants that the benefit of project import could not be given in respect of the goods imported for the Pamex Exhibition and the appellants were directed to revise the Bill of Entry. The appellants submitted the revised Bill of Entry dated 23/7/1983 and cleared the goods after paying the customs duty thereon at the normal rate. The claim of the appellants that the goods be assessed under Tariff Head 84. 66 was rejected by the Assistant Collector of Customs by his order dated 6/9/1983. The said order of the Assistant Collector of Customs was set aside on appeal by the Collector of Customs (Appeals) by his order dated 16/5/1984 on the ground that the contract had been registered on 6/6/1983, prior to the clearance of the goods for home consumption against the Bill of Entry filed on 20/6/1983 and the initial clearance under the Bill o