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14. The only contention of the assessee is that the impugned goods are not in zinc sheets within the category of description of items under Tariff Item 26B(2). They do admit that it is an intermediate product which is consumed inside the factory. It also admitted that Union Carbide and other battery manufacturers are manufacturing these sheets and also buying from outside. Admittedly, the assessee is also buying and getting it made from rolling mills from outside. The question is as to whether this has to be considered as zinc sheets or not. The assessee has attempted to show that product does not satisfy the ISI specifications. Further, it is noticed as per the findings of the Collector (Appeals) that the size of the zinc sheets manufactured by the assessee are more or less similar to ISI standards. The assessee has not produced any certificate from ISI to show that this product is not satisfying to its specifications. Moreover, in the case of Wetoco v. Collector of Central Excise - 1992 (62) E.L.T. 584 relying on earlier Supreme Court judgment, it has been held that ISI specification is meant for ensuring quality control and is not relevant for determining classification of goods and the classification of goods have to be done according to popular or commercial meaning. The fact that the product are being capitively consumed shows that they are goods as has been held in the case of Bhor Industries Ltd. v. Collector of Central Excise, 1989 (40) E.L.T. 280 as "actual sale in the market is not necessary, user in the captive consumption is not determinative but the articles must be capable of being sold in the market or none in the market as goods." Therefore, there is no doubt that the impugned product is goods, as also marketable. It is not the case of the appellant that the impugned goods do not have shelf life and they cannot be retained for long. They also admitted that it is used by the battery manufacturers but there only contention is that it is not understood as zinc sheets in the market. The assessee has not produced any affidavit of market users. The assessee is relying on the letter of Indian Non-Ferrous Metals Manufacturers' Association. In this letter, they have clearly indicated that the product is used as an inter-mediate in the manufacture of re-battery cells. They have not indicated in the letter that goods have been examined by them. Therefore, their opinion that the goods are not zinc sheets, is not acceptable evidence. On the other hand, the Department has adduced the evidence in the form of the affidavit of Sethi and has also shown through the admission of the assessee by their letter dated 19-9-1974 and also shown that there are other battery manufacturers who are getting these items manufactured from roller mills as zinc sheets. The question is as to whether these goods can be considered as zinc sheets. As the tariff item reads "plates, sheets, circles, strips and foils in any form or size". Therefore, it follows that sheets need not be in the form in which it is understood by the user but it can be in any form or size. In the case of Collector of Central Excise v. Oriental Timber Industries -1985 (20) E.L.T. 202, Tariff Item 16B of the erstwhile tariff came in for interpretation. The Hon'ble Supreme Court held that Plywood even though not trimmed or sand attracted duty within the said Tariff Item. The similar analogy has been drawn in respect of coated or laminated paper all sort as held to be dutiable under Tariff Item 17(2) of the erstwhile tariff as in the case of Union of India v. Babu Bhai Nyalchand Mehta as reported in -1991 (51) E.L.T. 180 as well as in the case of Laminated Packages Pvt. Ltd. v. Collector of Central Excise -1990 (40) E.L.T 326. The larger bench in the case of Guardian Plasticote Ltd., Calcutta v. Collector of Central Excise and Ors. -1986 (24) E.L.T. 542 (Tri.) analysed the tariff Item 17 dealing with the paper, all sorts and held Bituminized paper also to be coming in the category of paper. In the case of LML v. Collector of Central Excise - 1991 (51) E.L.T. 434, the Tribunal held that yarn or multi-filament yarn captively consumed by the assessee was dutiable under Item 18-11(1)(a) of erstwhile duty. In this case also the assessee contended that they were not selling the goods. The Bench held that the propensity of the goods being marketed is determinable factor and on various other grounds held it to be dutiable.