( 1 ) THE petitioner-Company is a manufacturer of PVC coated plastic paper known as wall paper. According to the petitioner, it was entitled to claim benefit under Notification No. 165 of 1970 dated 5/09/1970 which was amended from time to time by subsequent Notifications No. 46 of 1973 dated 1/03/1973 and 27 of 1974 dated 1/02/1974. The department was of the view that the aforesaid notifications were not applicable to the case of the petitioner because the PVC coated plastic papers were printed by using printing machine. The petitioner preferred five different refund claims and the same were rejected. The details are as follows : date of Period Amount Date of rejection 11-5- 19/04/1974 to Feb. 1975 81,934. 14 18-5-1978 11-5- 19/03/1975 to Feb. 1976 1,17,900. 89 20-5-1978 20-2- 19/03/1976 to Jan. 1977 1,24,882. 46 30-8-1978 01-3-1978 Feb. 1977 to Aug. 1977 22,595. 22 25-7-1978 01-3-1978 Sept. 1977 to Feb. 1978 11,850. 05 25-7-1978

( 2 ) THE petitioner preferred appeal against the said orders before the Collector, appeals who as per his judgment and order dated 10/08/1979 allowed the appeal holding that the printing of colour on the plastic paper would not mean employment