( 1 ) JAY Engineering Works Limited (petitioner No. 1) is a limited company having its registered office at Delhi. It owns a unit in Agra known as Agra Engineering Industries where it manufactures electric fans and regulators. According to the petitioner it is also manufacturing regulators for the fans at its Agra unit but it is stated by the respondents in the counter affidavit that the regulators are not manufactured by the petitioner but that the petitioner gets them manufactured from a unit named and styled as Bharat Kumar Bhargava by supplying them requisite raw-material. The electric fans and regulators are sold by the petitioner company to dealers appointed by it and also directly to customers from its own shops in the State of West Bengal and Andaman and Nicobar Islands. In respect of the rest of the country, however, about 90 per cent of its sales are effected to Usha Sales Limited (hereinafter referred to as "usha") and to some extent directly to bulk institutional buyers.

( 2 ) WE are concerned in this writ petition with the determination of the assessable value of the electric fans manufactured and sold by the petitioner for purposes of the Central Excise