Per Justice U.L. Bhat:

These appeals are directed against the common order in appeal No. 403 to 422/90 dated 19.7.90 passed by the Collector (Appeals) confirming the several orders passed by the Assistant Collector on 20 price lists filed by the appellant.

2. Appellant, M/s Escorts Tractors Ltd. was selling the entire production to M/s Escorts Ltd. till 31.12.80. With effect from 1.1.81 appellant started selling to other wholesale dealers also, the volume of such sales being 20% and the rest was being sold to M/s Escorts Ltd. Even during the period prior to 1.1.81, the department was treating the two concerns as related persons and demanding duty on the basis of the prices charged by M/s Escorts Ltd. wholesalers. This controversy was settled in favour of the appellant by the High Court of Delhi.

3. The dispute in these appeals relates to various price lists effective from 1.12.82 till 24.7.89. During the entire period about 80% of the sale were to M/s Escorts Ltd. and 20% to other independent dealers and the discount allowed to M/s Escorts Ltd. was higher than the discount allowed to other wholesalers. Some time in 1983, appellant purchased some shares of M/s Escorts Ltd. The ini