CHAGLA C. J. :

Although the ultimate question that we have to decide in this appeal lies in a very narrow compass, it raises certain questions of considerable public importance. The appellants before us are a company registered in India and they deal in antibiotics, Pharmaceuticals and foods, and for the purpose of their business they have been importing into India since about February 1951 large quantities from, Glaxo Laboratories Ltd., U. K. of Vitamin B. 12 in bulk of the value of several lakhs of rupees every year. The appellant company admittedly is a subsidiary company of the English company. From February 1951 to May 1955 the appellants entered in their bill of entry for the purpose of customs duty the invoice value of the goods. Between June 1955 to May 1956 they showed the real value of the goods as the wholesale price of the goods in the United Kingdom, and after May 1956 they reverted to their original practice of showing the invoice value. In this appeal we are concerned in all with ]0 consignments. The first six consignments arrived in India in April 1956 and September 1956 and the value of these consignments was shown in the bill of entry as £. 72-3-9 per gram.