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3. Learned advocate for the appellants has, however, urged as follows:-

3.1. Drilling rigs basically consist of some main components such as hoisting system, meet, draw works, rotary table, transmission gear box, pull down system, mud pump, hydraulic system and truck chassis, crawler tractor, skid, power-take-off device etc. 3.2. He also highlighted the process of manufacture of mounted drilling rigs on a motor vehicle chassis which is as follows:-
"that, the configuration of component, changes from model to model and they are based on the specifications given by the buyer; that the choice of mounting is also given to the buyer and the. mounting could either be on the skids, trucks, crawler tracks or trailer; that the customers requires the machine mounted skid, the assessee manufacture the complete machines including the skid and then comlete skid mounted drilling rig is supplied to the buyers; that where the buyers placed an order for the rigs mounted on truck or trailor, truck chassis is purchased from the truck manufacturers either by the assessee or in some cases by the buyers and supply the trucks to the assessee. In such cases, the chassis brought into the factory is altered by including certain parts specifically designed for integrating the chassis with the drilling rigs. Besides these, certain other structural alterations are carried out on the chassis so as to make the entire unit a complete integrated unit; that the unit is run by power which is supplied by the truck engine through the propeller shaft; they manufactures the power take off device which transfers the power from the truck engine to the machine; that the power to the unit is regulated from the drivers cabin and the speed can be increased or decreased through the accelerator; that for stopping the entire unit, the engine has to be started from the drivers cabin and thereafter the power flows through the power take off device which is installed by them by cutting the propeller shaft of the truck chassis.

3.3. He has also highlighted the following important technical aspects of the matter:-

"(a) The components of drilling rigs are not necessarily fitted/mounted on a truck chassis. The drilling rig components are mounted either on a truck chassis or trailor or skid, or crawler.
(b) The use of truck chassis is for the sole purpose of imparting mobility to the drilling rigs. Thus, it is obvious that the drilling rig is required for digging the earth etc. and for this purpose, it has to be shifted from place to place, for this shifting, the chassis is used.
(c) The truck chassis after receipt in factory requires to be modified substantially by cutting down its length, modifying the propeller shaft etc. The power from the engine of the chassis is also required to be transmitted to the drilling rig for the purpose of digging. This modification of the truck chassis is so substantial that after this modification and mounting of the drilling rig thereon, the truck chassis cannot be separated and used as a truck chassis again.
(d) The functional capacity and essential characteristics of the drilling machine as a whole is attributable solely to the drilling rig and not to the truck chassis. The said product is recognised and serves its purpose as a boring machinery and not as a vehicle that, in view of the above technical facts, it is obvious that the said product merits classification under Heading 84.30, as a machinery and not as a vehicle."

4. In his rejoinder, Shri Manoj Arora, learned advocate for the appellants has urged that the manufacturing process indicated by the appellants has not been rebutted by the adjudicating authority. They are manufacturing power-take-off Device which supplies the power from the engine of the motor vehicle chassis to the drilling rig, thus completely integrating the chassis and the drilling rig. Power source referred to at para 23 in the order placed by the Chief Public Health Engineer, Government of Assam and pointed out by the learned JCDR is only a small alternative arrangement for the purpose of lighting and not for the purpose of working the drilling rig.