The Order of the Court is as follows :-

The Petitioners in these Writ Petitions M/s. Motor Industries Co., Ltd., are a public limited company and have been carrying on businessinter aliaof the manufacture and sale of diesel fuel injection equipment and parts thereof at their factory in Bangalore. The petitioners imported two consignments of semi-finished crude steel forgings viz., camplates for distributor pumps and three consignments of crude steel forgings of adjusting pins used in governor assembly. The petitioners paid duty under Heading 84.10(3) at 100% plus 20% plus C.V. duty at Rs. 165/- per metric tonne. The petitioners made a refund claim before the Assistant Collector of Customs, Madras, contending that the goods imported by them attracted classification as

"other articles of iron steel not elsewhere specified' attracting 60% basic duty and 15% additional duty, and countervailing duty at Rs. 165 per M.T. in terms of Notification No. 254/CUS/76 and that the assessment made under Heading 84.10(3) at 100% plus and 20% was not proper and incorrect and hence made a claim for refund of the excess amount collected therefore. The Assistant Collector by his proceedings