Per A.C.C. Unni :

In this appeal filed against the order-in-original dated 6.12.94 by the Collector of Central Excise, Meerut, the questions raised before us relate to "manufacture" and limitation.

2. Appellants are a SSI unit manufacturing Zip fastners. They were exempted from payment of duty as well as licensing control under Notification No. 71/78 dated 1.3.78 and 80/80 dated 19.6.80. They were also printing on polyester films which, according to the appellants, were products which were chargeable to nil rate of duty. The appellants were issued a SCN dated 7.1.94 asking them to show cause why Central Excise Duty amounting to Rs. 10,10,395.65 should not be recovered from them as they had not taken out Central Excise licence for the manufacture of printed polyester films falling under sub-heading 3920.00 and as exemption for clearances of Rs. 15 lakhs in terms of Notification No. 175/86 dated 1.3.86 had ended on 3.11.88 and thereafter the clearances were to be effected on payment of duty at appropriate rate. The Department alleged that the appellants had in their classification list dated 10.4.89 mis-declared their turnover in 1988-89 as nil when they were asked to supply figu