P.C. Jain, Member (T)

1. Since the common issues are involved in both the appeals - one filed by the assessee and the other by the Collector - a common order is being passed.

2. Brief facts of the case are as follows :-

2.1 JMC Industries (hereinafter referred to as the assessee) are engaged in the manufacture of various types of motor vehicle parts falling under Tariff Item 68 CET. Besides manufacturing the above goods, the assessee is also importing forged crankshaft. The said crankshafts are thereafter sent by them outside their factory for machining, grinding etc. on job work basis. After the receipt of the crankshaft thus processed/manufactured by outside units the assessee undertakes the shallock process i.e. applying oil etc. to save the crankshaft from rusting. Thereafter they pack it before despatching to their customers.

2.1A. Before 15-1-1983 the assessee had included the value of the crankshafts manufactured on their behalf by the outside manufacturers and they were paying duty and the value of the crankshafts was also taken into account while computing the exemption limit of Rs. 30 lakhs in terms of Notification 105/80 dated 19-6-1980. Prior to 15-1-1983 the assessee