V.T. Raghavachari, Member (J)

1. As all these appeals raise a common question for determination, though the periods and the relevant Finance Acts relating to the different periods may be different, all these appeals were heard together.

2. The Indian Oil Corporation had exported certain petroleum products to Nepal without payment of duty under Bond claiming to be entitled to do so in terms of notification No. MF (DR) 151/81 dated 29-7-81 issued under Rule 13(2) of Central Excise rules, 1944. Subsequently, various show cause notices were issued as to why special excise duty should not be demanded from them in respect of such exports. They replied denying liability relying on the notification mentioned supra. Their denial of liability was rejected by the Assistant Collectors concerned. Their appeal against the said orders were rejected by the Collector (Appeals) under order dated 27-5-1985. It is against the said order that these 11 appeals have been filed. Apart from claiming that no special excise duty was payable as demanded, it is further contended that in any event the demand in respect of several of the instances was barred by time also.

3. We have heard Shri N.V. Raghavan Iy