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1. This is an appeal filed by M/s. Parle Products (P) Ltd., being aggrieved with the Order-in-appeal No. PAH-390/131-134, dated 3-7-1987, passed by the Collector of Central Excise (Appeals), Bombay. The matter relates to the inclusion of the cost of the capsul, fitted over the lid on the metal container, popularly known as KOT (Kerosin oil tin) container, in which the biscuits were packed. The appellants were availing exemption under Notification No. 34/83-C.E., dated 1-3-1983, which exempted among others, the biscuits from so much of the duty of excise leviable thereon as was equivalent to the duty of excise leviable on said biscuits, with reference to that part of the value of the said biscuits which represented the cost of metal containers, in which the said biscuits were packed, at the time of their removal from the factory. The contention of the Revenue is that the capsul was fitted on the KOT containers over the lid as an additional fitment, and did not form part of the metal containers, and that its cost was includible in the assessable value of the biscuits. On the other hand, the assessee had pleaded that the capsul was part of the KOT containers, and that its cost could not be added to the assessable value of the biscuits.