- (1.) The appellants manufacture aluminium wire rods out of duty paid aluminium ingots on behalf of various customers on a job work basis. This appeal is against the tribunal's order holding that handling charges on raw material collected by the appellants were includible in the assessable value of the goods. They were pre-manufacturing expenses. The contention that the appellants were covered by the Aluminium (Control) Order, 1970 was rejected, as was the contention that they were entitled to assessment at a price on the basis of like goods or equal to the statutorily fixed price where goods are sold by the assessee in wholesale trade. The tribunal pointed out that there was no sale by the assessee who merely converted aluminium ingots into wire rods and then returned them to the customers. It was further held that the demand was valid for a period of five years prior to the date of the show cause notice as collection of additional amount by debit notes showed a mala fide intent to evade duty. The grounds of appeal are whether the transportation charges recovered by the appellants from customers were includible in the assessable value without referring to the provisions of S. 4. Further, that the tribunal erred in rejecting the applicability of the Aluminium (Control) Order while adding a certain sum to the price determined under the price control basis. The demand, according to the appellants, was barred by limitation as there was no suppression of facts from the department.;