1. The present appeal dated 8-12-1979 as supplemented by a further communication dated 20-2-80 (originally filed as a revision application before Government and transferred to this Tribunal under Section 35-P of the Central Excise and Salt Act, 1944) has been filed by M/s. Shree Rayalaseema Paper Mills Ltd., Kurnool, who are engaged in the manufacture of varieties of paper including wrapping paper. The facts of the case are not in dispute but for a proper appreciation of the legal issues which flow from such facts, the same are briefly set out as hereunder :

2. When the appellants started production in their paper mill in April, 1979, the Assistant Collector of Central Excise, Kurnool vide his order dated 21-4-79 informed them that excise duty should be paid by them-(a) on wrapping paper produced by them prior to its use as wrapper for wrapping other varieties of paper, and (b) the value of such wrapping paper (including the duty element) should be added to the value of any other type of paper before the assessable value of such paper is determined. In other words, the Assistant Collector wanted the appellants to pay the central excise duty on the wrapping paper at two stages,