S.V. Maruthi, Member (J)

1. The appeal arises out of an order of Collector of Central Excise disallowing the deductions claimed by the appellants from the assessable value of synthetic detergent powder.

2. The facts in brief are the appellants M/s. Guljag Chemicals & Plastics Pvt. Ltd. engaged in the manufacture of Synthetic Detergent Powder. They entered to an agreement with M/s. Index Port Ltd. (I.E.L. in short) (wholly owned subsidiary of M/s. Hindustan Lever Ltd.) under which they produce and manufacture "wheel" detergent powder for and on behalf of Index Port Ltd., Bombay. IEL supplies all raw-materials including packaging material such as polythene pouches and HDPE bags and the appellants receive and hold all such material on behalf of IEL, carry out processing of these raw-materials into finished products as per the instructions of IEL, and pack the detergent powder under the brand name "wheel" belonging to IEL. The detergent powder is packed in retail pack size of 1 Kg. polythene pouches and 50 number of such polythene pouches and then packed in HDPE bags. The finished product is then despatched by the appellants to the specified destination as per instruction of IEL, an