1. The assessee is in appeal against an order of the Customs, Excise and Gold (Control) Appellate Tribunal.

2. We set out the facts only insofar as they relate to the three issues which are canvassed at the Bar.

3. The assessee, a cigarette manufacturing company, was issued a show cause notice on 26th August, 1983 in respect of its Bombay factory. A demand for excise duty in the sum of Rs. 28.93 crores was raised for the period 1978 to 1983. On 19th April, 1984 a second show cause notice was issued to the assessee. It was in respect of its Baroda factory. It related to period 1978 to 1983 and demanded Rs. 35.32 crores by way of excise duty. On 2nd September, 1985 a third show cause notice was issued to the assessee which related to its Bombay and Baroda factories. It sought to make the assessee and two of its job workers liable to excise duty in the sum of Rs. 13.37 crores for the period 1st July, 19