( 1 ) IN this writ petition the petitioners are challenging the validity and levy of excise duty in respect of sliver which is obtained by them as an in process material in the manufacture of woollen yarn in its factory premises.

( 2 ) THE petitioner-Company manufactures, inter alia, woollen yarn from raw-wool. The writ petition sets out the entire process of manufacture of woollen yarn from raw-wool.

( 3 ) BRIEFLY stated, according to the petition, the raw-wool purchased from the market is first of all opened in a cleaning machine and loose dirt, grease and vegetable matter is removed. This opened wool is thereafter cleaned and washed. The washed wool is dried and there after the partially dried wool is opened in a machine called the preparatory willow. This machine separates the wool fibres and further removes the dirt and vegetable matter which may have remained in it. Thereafter different types of wool are blended. At this stage, the wool is conveyed to the spinning department in the factory. In the said department humid conditions are maintained as the same are necessary and essential for further processing. The wool is then put on a carding machine. T