(1.) These are statutory appeals filed under Section 130(E) of the Customs Act, 1962 from the judgment and order dated 23.8.2005, passed by the Customs, Excise and Service Tax Appellate Tribunal, West Zonal Bench at Mumbai in Appeal No. C/791 & 792/03/Mum.
(2.) The appellants imported two consignments of "2-4-6 Tricloro 1-3-5 Triazine" aggregating 74.10 MT from China under two Bills of Entry, the cost of which is declared by the appellants to be SG $ 750/- PMT equivalent to US $ 500/- PMT. The goods were provisionally assessed and allowed clearance on 17.9.1994.
(3.) Subsequently, a show cause notice dated 25.9.2000 came to be issued to the appellants by the Commissioner of Customs, Gujarat at Ahmedabad calling upon the appellants to show cause why certain action indicated therein cannot be taken against the appellants. The relevant portion of the show cause notice is as follows:- "Therefore, M/s. Gira Enterprises, Ahmedabad are hereby called upon to show cause to the Commissioner of Customs, Ahmedabad as to why: