Per Justice K. Sreedharan :

Issues raised in these two appeals are identical. So we consider it advantage[ous] to dispose of them by this common order. For a proper understanding of the issued raised we refer to the facts in appeal 1798/98 in detail. Appellant there-in M/s. R.H.Industries is the manufacturer of Axle Beam Assembly which is a component part of Tractors manufactured by Punjab Tractors Ltd. While carrying out this job work of manufacturing Axle Beam Assembly they did not include the value of the Axle Beam Bushes supplied free of cost by Punjab Tractors Ltd. Therefore, on the allegation that appellant wilfully suppressed the value of Axle Beam Bushes while paying duty on the Axle Beam Assembly, show cause notice dated 1.2.95 was issued calling upon the appellant why sum of Rs. 3,16,913.05 should not be realised as the amount of duty evaded for the period from November 1990 to July 1995. Appellant herein objected to the show cause notice on many counts including the plea of limitation. The Adjudicating Authority by order in Original No. 95 CE ADC 97 dated 29.8.97 confirmed the demand. Aggrieved by that decision R.H. Industries preferred an appeal before the Commissio