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 Tyre International, the commissioning, erection, packing charges, engineering, design charges are part of the assessable value as they are charged for manufacturing activities connected with the items manufactured by the party. It was also held by him that the batteries are the integral part of the mechanism of the equipment/system manufactured by the party and therefore, its value should be included. Shri A. Hidayatullah, learned Senior Advocate, appearing for the party in all these cases submitted that aggrieved by the respective orders either on merits or in raising the demands on the above issues were challenged by the party before the Collector (Appeals). He said that Order-inappeal No. SKM-1457/89-B.1 dated 10.7.1989 is the basic order which decided the case on merits and subsequent orders in appeals were passed by the respective Collectors following the above order and set aside the orders relating to demand passed by the Superintendent or the Assistant Collector as the case may be and remanded them to the respective authorities to decide the correctness of the demand in the light of the Order-in-appeal No. 1457/89 dated 10.7.1989 after giving proper opportunity to the party. In the Order-in-appeal No. SKM-1457/89- B. 1 dated 10.7.1989, it was held that Engineering and design charges, drawing and documentation charges and packing charges are to be included in the assessable value but no installation and commissioning charges and issue with reference to forwarding charges it was remanded to the Assistant Collector to decide the matter on the basis of facts. As regards Battery charges it was held that since the battery is a component of the goods, its value shall have to be included in the total assessable value of the impugned goods and no deduction towards it can be granted. Shri Hidayatullah submitted that though the dispute was with reference to various charges before the authorities below, he would confine to cost of bought out items (Battery charges and others) since the party got relief in respect of installation and commissioning charges and is not pressing with reference to other charges in the appeals filed by the party. He said that while deciding the issue with reference to cost of bought out items, whether on installation and on assembly of UPS system at site of customer is 'goods' to attract duty or as such is immovable property is also to be considered since this ground was taken by the appellants in the appeals and miscellaneous applications filed by the party were allowed- permitting them to raise by way of additional ground as per Misc. Order Nos. 74 & 75/92A dated 21.3.92 in respect of the appeals wherein this ground was not specifically taken. In addition to these issues, time-barring issue is also to be considered since demand