G. Sankaran, J.

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. The appellants are manufacturers of wires and cables. They also produce, among other things, a substance which they describe as "PVC Compound" from out of duty-paid PVC resin. During the material time, namely, 18-6-1977 to 28-6-1977 they manufactured 31 M.Ts. of PVC compound and removed the same for captive consumption within the factory. On 15-12-1977, the Supdt. of Central Excise issued a Show Cause Notice to the appellants to show cause why the duty leviable on the goods-Rs. 1,21,768.00-should not be demanded from them in terms of Rule 10 of the Central Excise Rules (hereinafter referred to as the Rules.). In reply, the appellants submitted that they were manufacturing "granule" (PVC Compound) from duty-paid PVC resin, that these granules were a modified form of PVC resin, that they were not polymerisation or co-polymerisation products, that the process of conversion of duty-paid PVC resin