Per K.C. Mamgain : These (03) three appeals filed by M/s. ITC Ltd., Bangalore against the Orders-in-Appeal No. 704/2001-CE dated 31.10.2001 and 548/2002-CE dated 23.09.2002 (by this order two adjudication orders No. 22/2001 dated 28.9.2001 and No. 21/2001 dated 26.07.2001 were decided) passed by the Commissioner of Central Excise & Customs (Appeals), Bangalore. Since the issue involved in these three appeals is common, therefore, these were taken up together for hearing and are being disposed of by this common order.

2. The facts in brief are that the appellants are manufactures of slides and inner frames falling under chapter sub-heading No. 4823.90 and Aluminium inner frames falling under chapter sub heading No. 7607.30 of the Central Excise Tariff Act, 1985. They have filed price declaration under Rule 173C of the Central Excise Rules, 1944 in respect of these goods manufactured and captively consumed in their factory for packing of cigarettes and have declared the value under Section 4 arrived at by cost construction method by enclosing Chartered Accountant Certificate certifying the cost of material. It was found from the price declaration filed from 1995-96 onwards on cos