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1. These two appeals are filed by the assessee i.e. Elpro International Ltd. and their related person I.G.E. and both the appeals are disposed of by this common order as the issues are inter-connected.

2. The assessee (hereinafter referred to as Elpro) was incorporated in 1963 to manufacture low powered X-ray equipment, and some of the components and parts of high powered X-ray equipment of different models and specifications. It has L-4 licence, and manufactures portable and mobile low powered X-ray equipment. This X-ray equipment includes bought out items one of which is X-ray tubes which is manufactured by BEL. X-ray equipment thus manufactured is sold to I.G.E. I.G.E. in turn sell the low powered X-ray equipment to their customers viz; doctors, clinics and hospitals. Since Elpro do not have the facility to manufacture high powered X-ray equipment, they manufacture

5. I.G.E. was incorporated in 1930 and carrying on business in buying components/parts of electro-mechanical equipments, and engaged in private services such as installation, assembling, fitting, commissioning etc. They sell a complete electromechanical machine to their customers. It has 16 branches and four resident engineers all over India and 110 highly qualified technical personnel. They buy from Elpro X-ray tables, floor to ceiling X-ray column stand and X-ray generators comprising of controls and high voltage transformers. The X-ray tubes and high voltage cables which are essential in completing the X-ray equipment are purchased from BEL directly, store them in their godown at Bombay and Patna. According to them, a complete high or medium powered X-ray machine comprises of the following components/parts.

(i) Mechanical components/parts,

(ii) Various types of X-ray tables, like simplex (hand operated),

(iii) Horizontal rezent (power operated),

(iv) X-ray columns,

(v) Electric equipments/parts,

(vi) X-ray generator comprising of X-ray controls, and high voltage transformers,

(vii) X-ray tube units,

(viii) High voltage cables.

6. The components/parts thus, purchased from Elpro and BEL are tested, assembled, fitted, inserted and demonstrated at the customers site in pursuance of an agreement entered into with them.