Whether in the facts and circumstances of this case the Tribunal was justified in upholding the order of the commissioner dated with respect to a the excisability of the kimam ... and classification thereof under sub- heading prior to and under sub-heading w e f b rationale for invoking the extended period of limitation under the proviso to section A and c eligibility for the benefit of proforma modvat credit in respect of the chewing tobacco kimam is the question which arises for determination in these civil appeals filed by the appellant - assessee under section -L b of the Central Excise Act hereinafter referred to for the sake of brevity as the Act

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