G. Sankaran, Member (T)

1. The captioned appeal was initially filed as a Revision Application before the Central Government which, under Section 35-P of the Central Excises Salt Act, 1944, has come as transferred proceedings to this Tribunal, for disposal as if it were an appeal filed before it.

2. There will be occasion to refer to the facts of this case in some detail in the later part of this order and, therefore, it is proposed to set out at this juncture, only the salient facts. The appellants are manufacturers of Polyurethane Foam (P.U.F.) which is an article falling under Item No. 15A of the Central Excise Tariff Schedule (CET). For manufacture of PUF, they imported certain raw materials, namely, polyesters and polyether. These raw materials used to be assessed by the Bombay Customs authorities to basic customs duty as resins under heading No. 39.01/06 of the Customs Tariff Schedule and countervailing duty as resins under Item No. 15A of the CET. Item No. 15A CET has been one of the items in respect of which the benefit of rule 56A has been extended by the Central Government. Raw materials falling under Item No. 15A on which countervailing duty of customs or excise duty