Per. P.K. Kapoor: This is an appeal against the order passed by the Collector of Central Excise (Appeals), New Delhi. Briefly stated the facts of the case are that the appellants who are engaged in the manufacture of HDPE/PP Woven Sacks, filed a Classification List seeking the classification of HDPE/PP Woven Sacks under Subheading 6301.00 of the Central Excise Tariff. On the basis of the order No. 8/92 dated 24.11.92 issued by the Central Board of Excise & Customs under the provisions of Section 37-B, the appellants were served with a Show Cause Notice seeking the recovery of differential duty amounting to Rs. 4,31,838/- in respect of the clearances of the said goods effected from the factory during the period June, 1992 to November, 1992 on the grounds that the goods in question were classifiable under sub-heading 3923.90. The appellants contested the demand on the ground that the clearances during the relevant period having been effected on the basis of an approved Classification List no demand could be raised for the past period until the Classification List was revised and any revision of the Classification List could have only prospective effect. However,, by his order da