S. Duggal, Member (J)

1. The issue involved in this appeal, which was originally a revision petition before the Central Government, is as to the availability of benefit of Notification No. 119/75-C.E., dated April 30, 1975 to appellants, in respect to the manufacturing process they carried out on brass rods received from their customers, by making valves and nuts, meant for different parts of LPG cylinders.

2. The facts as set out in the appeal, and also as indicated by the Order-in-Appeal, reveal that the appellants received from certain named customers brass rods by way of raw material for the manufacture of forged nuts and valve body forged and machined on job basis during period 1-7-1975 to 31-12-1975. They paid duty on job work charges received by them from their customers, in terms of Notification No. 119/75, while the excise authorities took the view subsequently that value of the raw material had also to be included, inasmuch as the appellants manufacture complete equipment for cylinders, out of the raw material received from the customers, and as such, they had erroneously been allowed benefit of aforesaid Notification. Thus, a short levy demand on account of duty, on f