JUDGMENT

Dipak Misra, J.

The present appeals have been preferred against the judgment and order dated 30th June, 2003 passed by the Customs, Excise and Service Tax Appellate Tribunal (for short, “the tribunal”) in Application Nos. C/MA (Ors.) 945/01-Mum in C/716, 781, 782, 814/01-Mum by the revenue as well as the assessee as both are aggrieved in respect of certain conclusions arrived at by the tribunal. As the principal controversy pertains to the appeals preferred by the department, we will take the facts from the appeals preferred by it and, accordingly, we shall describe the parties.

2. The first respondent, M/s Aban Loyd Chiles Offshore Ltd., engaged in business of offshore oil and gas exploratory drilling and related activities on contract basis, inter alia, for the Oil and Natural Gas Corporation Limited (ONGC) had obtained the approval of the Government of India on 25.03.1987 for the import of a Rig for such oil field services. It was granted a Special Import Licence bearing number P/CG/2103211 dated 24.04.1987 for the import of the said Rig along with certain drilling equipments. A confirmed irrevocable Letter of Credit amounting to US $ 1,521,000/-for the shipment of Capit