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K.L.REKHI, HARISH CHANDER
Kerala Electric Lamp Works Ltd. – Appellant
Versus
Collector of Central Excise, Cochin – Respondent
K.L. Rekhi, Member (T)
1. The main controversy in these appeals is whether M/s. Crompton Greaves Ltd. (hereinafter referred to as 'Crompton') were a "related person" of M/s. Kerala Electric Lamp Works Ltd. (hereinafter referred to as 'assessee') within the meaning of Section 4(4)(c) of the Central Excises and Salt Act, 1944. There are certain other subsidiary issues also. But since the issues are common and inter-connected and related to the same assessee, they were argued together before us. This combined order will dispose of all the 15 aforesaid appeals, 14 of the department and one of the assessee.
2. The essential facts are that the assessee manufacture electric bulbs, fluorescent tubes and MV lamps. The dispute before us is regarding valuation of their goods for the purpose of assessment of central excise duty. The period of dispute is from 18-3-1978 onwards. Daring this period, Crompton were the principal distributor of the assessee. They lifted around 80% of the assessee's production. As per agreement between the two parties, Crompton kept Rs. 15 lakhs with the assessee as a security deposit. During the period from 18-3-1978 to 13-8-1978, the assessee was manufacturing t
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