P.C. Jain, Member (T)

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

1.1. The respondents, the Joint Sector Public Limited Company of the Government of Andhra Pradesh, manufactures a product known as asphalt corrugated roofing sheets (hereinafter referred to as ACR sheets). The factory of the respondents was established in 1970 and started its production in 1971. The process of manufacture of ACR sheets is described as follows in the appeal filed by the appellant-Collector :-

"Waste paper obtained from road pickings is covered into pulp and formed into sheets. These paper sheets are dried in the sun and corrugated by the machine. These corrugated paper sheets are also called as 'Base Mats'. These base mats are impregnated with asphalt and finally painted with aluminium paste. The final product is known and marketed as ACR sheets. Thus the corrugated boards after impregnating with asphalt are conferred with special properties of thickness. Water proof, fire resistance, and therefore are specially treated paper boards."

1.2. On 25-5-1974, the Superintendent of Central Excise issued a memo to the respondent company stating that it had been decided to bring their factory under Central E