( 1 ) THIS is an appeal from an order under Article 220 of the Constitution. The respondents imported a quantity of Armco Nestable Steel Culverts complete with accessories required by the Government of Assam under an import license issued to the Chief Engineer, Public Works Department, Assam. The respondents duly submitted a bill of entry in accordance with Section 29 of the Sea Customs Act, 1878 (Act VIII of 1878) stating the real value, quantity and description of the goods. They contend that the goods are assessable to customs duty under item 63 (9) o the first schedule to the Indian Tariff Act, 1934 (Act XXXII of 1934 ). By an order dated the 30th June, 1955 the Assistant Collector of Customs for Appraisement rejected the respondents' contention and assessed the duty under item 63 (28) of the first schedule to Act XXXII of 1934. The duty so assessed amounts to Rs. 73315/8/ -. The respondents appealed to the Collector of Customs, Calcutta. Pending the appeal they deposited the sum of Rs. 73315/8/- with the Collector of Customs under protest as required by Section 189 of the Sea Customs Act. By an order dated the 11th July, 1955, the Collector of Customs dismissed t