JUDGMENT :

DEEPAK ROSHAN, J.

1. Since common issue is involved in all these writ applications, as such all are heard together and disposed of by this common order.

2. The petitioner in all these writ applications have initially challenged the respective show cause notices (SCN) of the year 1994 to 1997 and the respective notices of personal hearing issued in the year 2022, i.e. after a lapse of about 27 to 29 years.

During pendency of these writ applications the respondent-Department vide its common Order in Original (OIO) dated 17.2.2023; confirmed the demand as made in the respective show-cause notices. The petitioner thus filed interlocutory application in respective applications which was allowed by this Court and the common Order in Original dated 17.2.2023 confirming the demand in the respective show-cause notices has been impugned.

3. It may be noted at this stage itself that the personal hearing notices was issued in respect of 11 show cause notices; against one such notice dated 9.12.1993 for the period June, 1993 to November, 1993, the petitioner had moved this Court in W.P. (T) No. 308 of 2023. This Court vide its order dated 14.2.2023 quashed the show cause notice along with the notice of personal hearing on the ground of inordinate delay.

For brevity the details of show cause notices and its period is mentioned herein below in tabular chart.

4. Brief chronology of events and the dispute involved in all these writ petitions is common, as such the fact and reference of W.P. (T) No. 826 of 2023 has been taken in the account. The remaining petitions are identical in all aspects except for the period in dispute involved for which a tabular chart had already been cited in the preceding paragraph.

Petitioner Company is primarily engaged in the manufacture of Iron and Steel, and in order to carry out its manufacturing activity, it has developed a separate wing, popularly known as 'Growth Shop' (Maintenance Shop), through which Petitioner used to get some of its Plants and Machinery manufactured/assembled/installed.

The petitioner issued work order to its Growth Shop for manufacturing, assembling, erecting and testing Electronic Overhead Cranes (for short 'EOC') for installation in the main Steel Plant of the petitioner at Jamshedpur. At the relevant point of time, excise duty was payable at different rates on parts of Crane and Crane, which were as under:

5. Earlier, a Show Cause Notice dated 08.02.1984 was issued to the petitioner by the Collector of Central Excise, Jamshedpur stating inter-a