JUDGMENT : 1. The appellants manufacture electrical appliances and sell them to wholesale dealers under brand names belonging to the wholesale dealers. The brand name are affixed to the electrical appliances manufactured by the appellants pursuant to the orders placed by the wholesale dealers. The assessing authorities originally approved the price list submitted by the appellants on the basis that the appellants were manufactures on their own account and the value of the goods manufactured by them was the wholesale cash price at which they sold the goods to the wholesale dealers. These price lists were accepted by the assessing authorities, but at a subsequent date, show cause notices were issued by the assessing authorities calling upon the appellants to show cause why they should not be treated as having manufactured the goods on behalf of the wholesale dealers since at the time of clearance from the factory of the appellants, the goods bore the l brand names of the wholesale dealers. The show cause notices also sought to assess the appellants on the basis that the wholesale cash price at which the goods were sold by the wholesale dealers should be taken to be the value of the goods for the purpose of levy of excise duty. The appellants filed their written statements in answer to the show cause notices and contended that they were manufacturers of the goods on their own account, that the wholesale cash price at which they sold the goods to the wholesale dealers was liable to be taken as the value of the goods for the purpose of levy of excise duty and that the value of the brand names should not be added to the wholesale cash price for determining the excisable value. The contentions raised by the appellants were rejected by the Assistant Collector. On appeal being filed, the Appellate Collector confirmed the demand for differential duty from the appellants. Aggrieved by the order made by the Collector, the appellants carried the matter in revision to the Government of India but the Government by its order dated 19th March, 1977 rejected the revision application and confirmed the demand made by the Assistant Collector. The appellants thereupon preferred the present appeal with special leave obtained from this Court. 2. Aggrieved by the order made by the Collector, the appellants carried the matter in revision to the Government of India but the Government by its order dated 19th March, 1977 rejected the revision application and confirmed the demand made by the Assistant Collector. The appellants thereupon preferred the present appeal with special leave obtained from this Court. 2. The questions arising in this appeal are concluded by two decisions 3 of this Court, namely, Union of India & Others v. Cibatul Limited, 1985 (22) Excise Law Times 302 (SC) and Joint Secretary to Govt. of India v. Food Specialities Ltd., 1985 (22) Excise Law Times 324 (SC). It is clear on an application of the principles laid down in these two decisions that the appellants manufactured these goods on their own account and not on behalf of the brand name owners and the assessable value of the goods manufactured by the appellants was the wholesale price at which the appellants sold the goods to the brand name owners and not the wholesale price at which the brand name owners sold the goods to others. The appellants could not therefore be assessed to excise duty on the basis of the value of the goods being taken to be the wholesale cash price at which the goods were sold by the wholesale dealers who were the brand name owners and to whom the goods were sold by the appellants. It is only the wholesale cash price at which the goods were sold by the appellants to the wholesale dealers who were brand name owners that was liable to be taken as the value of the goods for the purpose of levy of excise duty. 3. We therefore allow the appeal, set aside the order passed by the Government of India as also the orders passed by the Assistant Collector and the Collector confirming the demand for differential duty from the appellants and quash the demand made against the appellants. If any amount in respect of such differential duty has been recovered by the respondents, such amount shall be refunded to the appellants within six weeks from today. The appeal is disposed of accordingly with no order as to costs.