The point emerging for consideration in both these actions against common respondents is exactly the same and therefore, they are taken up for consideration in this common order, although the petitioner is distinctively different.

2.M/s. Paper Products Ltd., Madras-42 (for short PPL -petitioner in the former WP) is registered as a limited company under the Indian Companies Act, carrying on business, inter alia, of processing and supplying wax papers to customers and printing of papers and waxing them. It is licensed under the Central Excise Law. Excise duty, it is said, had been levied and collected in respect of transactions of processing and supplying of wax paper to customers and printing of papers and waxing them under Tariff Item No. 17(2) of the First Schedule to the Central Excises and Salt Act, 1944 (Act 1 of 1944 -for short CESA). Coming to know that such a levy and collection is not legally permissible, inasmuch as waxing of base paper, subjected to Excise Duty can, by no stretch of imagination, be construed as a manufacturing process, thereby converting the wax paper, a new product again exigible to Excise Duty under the very same Tariff Item 17 (2), as said ab