Exemption notification interpretation and effective duty rate brought the dispute within Special Bench jurisdiction, leading to remand.

Jurisdiction depended on whether the dispute involved only a factual question on emergence of an intermediate plastic film or also required interpretation of an exemption notification and the effective rate of duty. The jurisdictional objection failed because the case raised questions of notification interpretation, duty rate, and assessment correctness, bringing it within the Special Bench's scope. On the merits, the appellants limited their contest to the correct duty position and accepted that the final and intermediate product assessments were interlinked. As the exemption issue under Notification No. 217/86 had not been examined earlier, the matter was remanded for reconsideration at the adjudicating stage with liberty to make submissions consistent with that undertaking.

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Issues: Whether the appeal lay before the Special Bench in view of questions concerning interpretation of an exemption notification, effective rate of duty, and correctness of assessment.

Analysis: The jurisdictional objection was rejected because the dispute was not confined to a mere factual inquiry on whether an intermediate plastic film came into existence. The matter also involved interpretation and application of exemption notifications and the effective rate of duty, which brought the case within the Special Bench's jurisdiction. On the merits, the appellants gave up the dispute on the emergence and excisability of the intermediate film and sought determination only of the correct duty position. The assessment of the final product and the intermediate product were treated as interlinked, and since the exemption question under Notification No. 217/86 had not been considered earlier, the matter required reconsideration at the adjudicating stage.

Conclusion: The Special Bench had jurisdiction, and the matter was remanded for consideration of all relevant aspects with liberty to the appellants to make submissions consistent with their undertaking.

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