S. Venkatesan, Sr. Vice-President

1. This is a revision application (hereinafter called "appeal") filed before the Central Government which under Section 131B of the Customs Act, 1962, stands transferred to this Tribunal to be disposed of as if it were an appeal presented before the Tribunal.

2. The goods in this case are what the appellants have described as "E class electrical grade insulating papers". They were classified by the Customs authorities under Heading No. 39.01/06, relating to artificial resins and plastic materials, etc. The appellants claimed reassessment under Heading No. 48.01/21, relating to paper and paper-board and articles thereof. Their claim was rejected by the Assistant Collector, who held that the assessment under Heading No. 39.01/06 was in order. Their appeal to the Appellate Collector was rejected for reasons which will be mentioned later. Against this order of rejection the appellants filed a revision application which now stands transferred to the Tribunal.

3. Appearing for the appellants, Shri Sogani argued the case in great detail. Before setting out his arguments, it would be useful to take note of two previous orders of the Tribunal.

4. In its or