( 1 ) THE petitioner is a firm which carries on the business of manufacturing and of selling vegetable non-essential oils at Agra. It owns a factory known as Ganga Dhar Ram Chandra Oil mills where it manufactures vegetable non-essential oils and on such manufacture pays excise duty under the Central Excises and Salt Act, 1944. In addition to this, the petitioner takes oil seeds belonging to it to certain other oil mills, gets the oil manufactured thereon payment of the necessary manufacturing charges and takes the oil so manufactured and sells the same. These other oil mills are quite independent of the petitioners and of the petitioner oil mills. The vegetable oil manufactured by these other oil mills out, of oilseeds supplied by the petitioner was allowed to be removed by respondents without payment of any excise duty since the total quantity of oils produced by each one of these oil mills was within the exemption limit of 75 tons. Subsequently the respondent No. 3 appears to have taken the view that the vegetable non essential oil manufactured by these other oil mills out of oil seeds supplied by the petitioner was also liable to excise duty in respect of the oil