( 1 ) MOHITE, J. This petition is filed by M/s. Colfax (India) Pvt. Limited (hereinafter referred to as "the petitioners") against an order dated 11. 6. 05 passed by the Excise Inspector, Incharge, M/s. Colfex Laboratories (India) pvt. Ltd. , confirming a demand of Rs. 29,21,59,143/- from the petitioners being the excise duty payable by the by the petitioners for the period 9. 9. 91 to 17. 8. 98 and directing the petitioners to pay the said amount.

( 2 ) THE present petition has a chequered history which will have to be narrated, as it would be necessary to decide some of the points which have been raised in the petition.

( 3 ) A brief chronology of facts which gives rise to the filing of this petition, is as follows :

(a) On 15. 4. 1968, the petitioners were granted a licence for manufacture of various types of cosmetics, including an after shave lotion to be marketed under the trade mark "old Spice".

(b) On 1. 4. 1969, the petitioners were granted a further licence under the Medicinal and Toilet Preparations (Excise Duties) Act, 1955 for manufacture of "old Spice" as a toilet preparation.

(c) Till the end of 1984, the petitioners paid excise duty on "old spice" after shave lotion

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