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TMI Blog1979 (6) TMI 49X X X X Extracts X X X X X X X X Extracts X X X X ..... ed the point. raised by the petitioners in the revision application and those urged during the course of personal hearing and have examined the records of the case. 2. The petitioners manufactured what they described as three-in-one oil during the period when Item 11B of the Central Excise Tariff upto the period when the said entry was further amended in the 1972 Budget. The product in question ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xamined the question. Government agree that blending and compounding of lubricating oils are distinct processes and in case the product in question cannot be treated to be a compounded lubricating oil it would go outside the scope of Item 11B as it stood during the relevant period. The basic question therefore, that arises for consideration is whether the product in question was a compounded lubri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ents in the preparation of a product of specified properties, and compounding is defined as operation of blending vegetable for mineral oils in order to confer qualities necessary for particular applications. Compounding refers to mixing of mineral oils with a variety of materials ranging from animal vegetable and fish oils to sulfur soaps and chemical compounds to improve the lubricating properti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from 1-3-1972 when the petitioners started paying duty on the product in question, the price however remained only Rs. 3/- and was enhanced only somewhere in the year 1974. It is therefore contended that even if they were to pay duty during the relevant period, the price at which the goods were ultimately sold would have remained only Rs. 3/- and thus they have accordingly requested that the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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