JUDGMENT

Arijit Pasayat, J.—These two appeals are directed against a common judgment of the Central Excise and Gold Control Appellate Tribunal, New Delhi, (in short the CEGAT). Respondent (hereinafter referred to as the assessee) preferred the appeals before the Tribunal against a common order dated 31.3.1997 passed by Commissioner of Central Excise, New Delhi (in short the Commissioner). The issues involved in the appeals were (a) the valuation of "packaged type Air Conditioner" and (b) whether the extended period of limitation is invokable in demanding duty. The basic facts in a nutshell are as follows:

2. The respondent is engaged inter alia in the manufacture of, inter alia, package type Air Conditioners falling under Tariff Item No. 29-A of the erstwhile Tariff and Chapter heading No.84.15 of the Central Excise Tariff Act, 1985 (in short the Tariff Act). According to the appellant, the respondent was selling the air conditioners by assembling the same at site through orders procured from various authorities by way of Tenders/Contracts. The Contracts/Tenders entered into by the assessee are broadly divided into nine components:

1.Compressors

2.Accessories

3.Pumps

4.Cooling Towers

5.H