PER: C J MATHEW

The fine issue in this dispute, brought before us by the two categories of appellants against two sets of orders of Commissioner of Central Excise & Customs, Belapur, is also a crisis of existence. On the one hand is an, indubitably success, business model for manufacture of a niche product in which quality and precision of very high order is of essence. On the other is one silo in the larger scheme of tax levy that has ensconced a particularity, and as an afterthought, at that, in the scheme of valuation for computation of levy that the adjudicators opined as having been skirted with deliberate intent. And on that rests the outcome in the orders of Commissioner of Central Excise &

Customs, Belapur impugned here.

2. The resolution of the dispute has its locus in the fitment adopted by the adjudicating authority that the cavil of appellants portray as emanating from conjecture and not facts. Briefly, M/s Standard Greases & Specialities Pvt Ltd manufactures ‘lubricants’ for automotives and, in particular, ‘engine oil’ in accordance with requirements of the other appellants; products emerging from calibrated mixing of ‘additives’ to ‘base mineral oil’ and the ‘additives’