K.L. Rekhi, Member (T)

1. These six appeals have been filed by the department. They are inter-connected and deal with a common issue. They are, therefore, being disposed of by this combined order.

2. The common issue involved is regarding valuation of the motor vehicles manufactured by the respondents for the purposes of assessment of central excise duty and determination of consequential refund due to the respondents as a result of the Madras High Court judgment. This judgment was in favour of the respondents and had declared that main dealers of the respondents were not their related persons.

3. The present controversy started with the coming into force of the new Section 4 of the Central Excises and Salt Act, 1944 on 1-10-1975. In accordance with the requirements of the new section, the respondents, by their letter dated 23-9-1975, disclosed their marketing pattern in the following terms :-

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"2. DISTRIBUTION PATTERN

Our products in Clause 1 above manufactured at our works at Ennora, Madras are distributed to our various customers all over India through dealers net-work covering all the States. At the moment there are 13 independent Main Dealers, all non-relate