G.P. Agarwal, Member (J)

1. Out of the six appeals in hand, five appeals relate to classification of the goods and one appeal relates to the rejection of refund claims lodged by the appellants.

2. Factual backdrop: It is the case of the appellants that they accept on contract basis from the State Electricity Boards, in the country to install Electric Power Transmission Towers made of Steel for public distribution of Electric Power. For this purpose, they received from the Steel Authority of India Ltd., Tata Iron Steel Co. Ltd., and Indian Iron Steel Co. Ltd., duty paid steel angles falling under Tariff Item 26AA of the C.F.T. in their factory , cut them to size, punched and galvanised them and cleared them from the factory, and after clearance from the factory these steel angles were used in the construction of steel Power Transmission Towers of the State Electricity Boards, Government Body's like National Thermal Power Corporation Ltd. and National Hydro Electric Power Corporation Ltd. They submitted their five classification lists contending that since the steel angles had already paid duty under T.I. 26AA, and mere cutting, punching, and galvanising the cut-to-size angles