K. S. Puttaswamy, J.

( 1 ) ON a reference made by Hakeem, J. these cases were posted before us for disposal.

( 2 ) AS common questions of law arise for determination in these cases, we propose to dispose of them by a common order.

( 3 ) THE petitioners are manufacturers of polythene products, for the manufacture of which they import a base material called High Density Polyethylene Moulding Powder (HDPM) from united States of America, Brazil, Korea and other foreign countries. The material bought by the petitioners from their foreign sellers is transported by ocean going ships under Cost, Insurance, freight (CIF) contracts and are delivered at one or the other sea port of the country. From the concerned seaport, evidently at the request of the petitioners the HDPM was further transported by rail or road to Bangalore at which place the same was kept at the bonded warehouse of the customs department of Government of India to ensure payment of import duty under the customs Act of 1962 (Central Act No. 52 of 1962) (the Customs Act ). As to the payment of import duty payable on such HDPM, the petitioners claim that the demands made or to be made by the revenue were unauthorised in who

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