Per G.A. Brahma Deva : These are 25 appeals, 19 are filed by the party and remaining 6 are filed by the Department with reference to the respective impugned orders involving common issues. Hence, this common order.

2. M/s. National Radio & Electronics Co. Ltd., are a registered Company and are engaged inter-alia in the business of supplying and installing uninterrupted power supply system (UPS). They are engaged in the supply and erection of uninterrupted power supply systems, that is, system which are erected and installed in the customer's premises, which ensure that even if the supply of power from the main is cut off or interrupted, the same is substituted for by the power supply from the uninterrupted power supply system (UPS). On the plea that a contract for setting up of a UPS for a customer is a multifaceted and multi-activity contract involving various items, they claimed deduction on account of Engineering and design charges, documentation and technical charges, Installation and commissioning charges, packing and forwarding charges, bought out items like battery charges etc. The concerned Assistant Collector held that in view of the judgement in the case of Bombay Tyr