Per Jyoti Balasundaram :

The appellants herein are engaged in the manufacture of automatic data processing machines and computer peripherals and parts thereof. With the introduction of the CETA 1985, w.e.f. 1.3.86, they had been classifying computer peripherals under Heading 84.71 and seeking exemption under Notification 64/86 dated 10.2.86. For the period in dispute viz. 8.3.86 to 28.2.87, they filed a classification list No. 1/86-87 w.e.f. 1.3.86. They filed a classification list No. 1/86-87 in which they classified computers and peripherals under Heading 84.71 and claimed exemption from basic duty in terms of Notification 64/86 and exemption from special excise duty under Notification 171/86 and 175/86. They also furnished a complete list of entire range of peripherals manufactured by them, as annexure to the classification list which was approved on 30.5.86. A show cause notice dated 25.2.91 was issued to the assessees proposing recovery of Rs. 56,61,926/- on the ground that computer peripherals fell for classification under Heading 84.73 and were not entitled to the benefit of exemption under Notification 64/86 since this Heading was not specified in the Notification. The