1. The Appellant firm imported a consignment of what was described in the covering invoice as "Pole-end-plate forgings-Rough machined pole and plate forgings for generator parts Drg. No. 3-68-0006 through the port of Bombay. The Customs authorities classified the goods under heading No. 73.33/40 which read at the material time as follows :-

"73.33/40-other articles of iron or steel"

The appellants cleared the goods on payment of customs duty so assessed at 60% ad valorem (Basic Customs duty) plus 15% ad valorem (Auxiliary Customs duty). Later on, they filed a refunded claim before the Assistant Collector of Customs seeking re-assessment of the goods under Customs Notification No. 182/78 on the ground that the subject goods were required as parts for the assembly or manufacture of synchronous condenser of rating 30 MVAR.' The A.C. rejected the claim as unsubstantiated on the ground that the documentary evidence asked for by him was not produced by the Appellants. Against this order the appellants preferred an appeal which the, Appellate Collector of Customs rejected on the ground that the imported items were not finished items and therefore they could not be deemed as parts withi