Per Justice U.L. Bhat : Appeal E/1047/94-A, though not posted for hearing along with Appeals E/435/96-A and E/436/96-A, has been heard along with the other appeals on the representation of both the sides that they are connected and may be heard and disposed together.

2. The common appellant undertakes manufacture of Printed Polyester films to make packing pouches falling under sub-heading no. 3923.90 of the Schedule to the Central Excise Tariff Act, 1985. Printing of films is done through the medium of Gravure Printing Cylinder. Cylinders are manufactured by fixing S.S. Shell of cylindrical shape over a pipe of stainless steel and the shell is subjected to copper electroplating. Designs of customers' choice are developed and computer transmitted on to the cylinders. The process involves a high degree of precision, expertise and artistry. Cylinders are manufactured to suit the needs of individual customers and thereafter P.P. films and pouches are manufactured and delivered to customers. Cylinder is covered by tariff sub-heading 5442.00. The prices of cylinders and films and pouches are fixed separately and a part of the price of cylinders (sets of four or five) is collected in