( 1 ) THIS is a case where the facts ultimately resolve to be simple and undisputed, though the money value involved in the subject matter of the litigation is quite large.

( 2 ) THE matter arises in this way-the petitioners, that is, Hindustan Copiers Ltd. , who call themselves H. C. L. Ltd. , produce and sell copying machines. These are at present quite in demand in the market. For the purpose of their business the petitioners brought in consignments relating to 1,400 copier machines of which 1,000 were of the model known as BD-3110 and 400 were of the model BD-5100.

( 3 ) THESE machines were not brought into India as complete machines. They came into the country in a semi-knocked down condition called technically S. K. D. condition. The consignments were received in different ports and different airports. The dates were also naturally different in this regard.

( 4 ) THE petitioner has agreed and conceded before this Court, as it has agreed and conceded before the adjudicating authority, that excepting for the photo-copier drum these separate consignments could be assembled into the complete photo-copying machines of the above description, (of course, without th