(1) MR Harish N. Salve, the learned counsel for the appellant, urged a submission which is not found in the order impugned herein namely that the deduction is claimed on the basis of the equalised insurance and that the equalised insurance works out to be 20 paise. We find that the case proceeded before the tribunal on the assumption that the insurance charges incurred were only Rs. 17.45. The extra amount was claimed on account of overhead charges which the tribunal held rightly are not liable to be deducted. We, therefore, cannot allow Mr Salve to raise the said new question. We do not express any opinion on the question of levy of penalty. The appeal is dismissed accordingly. No costs.