K.L. Rekhi, Member (T)

1. The common issue involved in these three appeals of the same appellants is whether Carbide Throw Away Inserts manufactured by the appellants fall under Item 51A (iii) of the Central Excise Tariff, as urged by them, or under Item 62, as held by the lower authorities. The two rival items of the Tariff read as under :-

"51A (iii). Tools designed to be fitted into hand tools, machine tools or tools falling under sub-item (ii), including dies for wire drawing, extrusion dies for metals and rock drilling bits;"

"62. Tool tips, in any form or size, unmounted, of sintered carbides of metals such as tungsten, molybdenum and vanadium."

The Bench pointed out to the appellants that one of their appeals had been entirely allowed by the Appellate Collector on the ground of time-bar and in view of that whether they would like the Bench to consider all their three appeals. The appellants stated that they would like to argue on all the three appeals because even the Appellate Collector had rejected all their appeals on the substantive issue of classification.

2. The appellants produced samples of Throw Away Inserts as well as Tool Tips manufactured by them, explained the p