1. This appeal was filed by M/s Tata Iron and Steel Company Limited, Jamshedpur directed against an order passed by the Appellate Collector, Central Excise, Calcutta dated 30-7-1979 whereby he rejected the appeal of the appellant-company on the point of classification, of their products which they described as "(1) harrow discs and (2) coal-cutting picks, falling under Tariff Entry 26AA of the Central Excise Tariff, (hereinafter referred to as C.E.T.).

2. It appears that the aforesaid two products are being manufactured in a factory owned by the appellant company, under the name and style of "Agrico", where agricultural implements are produced by forging process, out of duty paid steel materials. It is contended that no duty is leviable on such forged products of iron and steel if made out of duty paid semi-finished steel material.

3. According to the appellant, they have been manufacturing number of products at the said factory under AL-4 Licence which they held since 9-12-1968, but when sometime in 1976, an application was made, in the usual course, for renewal of the aforesaid licence, they were advised by the Assistant Collector, Jamshedpur vide his letter dated 16-2-1976 th