(1.) BRIEFLY stated relevant facts of the case are as follows : -
(2.) THE respondents had applied for grant of licence to manufacture recorded audio compact discs in their 100% EOU, vide their application dated 15 -9 -1989 wherein the respondents explained the processes that would be undertaken in the EOU.
(3.) A show cause notice dated 4 -5 -1994 was issued to the respondents proposing to demand duty of Rs. 38,67,300/ - on the imports of Compact Discs and jewel boxes and trays on the ground that the activity undertaken by the respondents at the EOU did not amount to manufacture of goods. The longer period of limitation under Section 28 of the Customs Act, 1962 was also invoked.