M. Santhanam, Member (J)

1. As common question of facts (and) of law are involved in all these appeals, they were taken up together and are being disposed of by this common order.

2. The appellants in Appeal No. 322/85 and the respondents in the other appeals fabricate steel structures out of duty-paid materials supplied to them by Visakhapatnam Steel Project (hereinafter called as VSP). They have entered into contracts for the supply, fabrication and erection of structural steel and cladding works of Rolling Mills and Steel Melting Shop ( a shed ) in the project area. The above firms are contractors doing the fabrication work at the site allotted to them in the project area of VSP with their own machinery and workers. Show cause notices were issued to them on the basis that these contractors fabricate steel structural from out of iron and steel products like plates, angles, joists, channels, rods and strips as per the specification of VSP. The steel structural so fabricated are shifted to the project site for the erection of the shed aforesaid. According to the Department, these steel structural fabricated from the iron and steel produces by cutting, drilling holes and welding