- (1.) The appellants who are manufacturing epoxy-cast components i.e. crotch belly, bushing etc. submitted a classification list in the year 1987 for the said articles contending that they were classifiable under Sub-Heading 3926.90. For other articles, namely, insulating fittings for electrical machines, appliances or equipment, being fittings wholly of insulating materials, being manufactured by the appellant, they were classifiable under Heading 85.47. On that classification list the following endorsement was made by the officer concerned: "The party is engaged in the manufacture of glass-reinforced laminates which are being used as insulating material and is of the view that these are classifiable under Chapter Sub-Heading 8547.00. But the goods are correctly classifiable under Chapter 7014.00 as per Board's clarification vide Letter No. F No. 132/3/87-CC 4 (Circular No. 8187- CC4) dated 6-7-1987. It is therefore requested that the matter may please be considered at a higher level and proper procedure of natural justice may be followed for the finalisation of the classification list."
(2.) It is contended that after checking the same, the Department accepted it.
(3.) Thereafter, a show-cause notice was issued raising demand and for changing the classification. After adjudicating the demands, a penalty was imposed. Hence, the appellants preferred appeals before the Customs, Excise and Gold (Control) Appellate Tribunal, New Delhi (for short "the Tribunal").;