ORDER : 1. Revenue has filed the present appeals under Section 35 L(b) of the Central Excise and Salt Act, 1944 (for short ‘the Act’) against the final Order Nos. A-383-384/KOL/2002 dated 18.2.2002 passed by the Customs, Excise and Gold (Control) Appellate Tribunal, East Zonal Bench, Kolk at a (for short ‘the Tribunal’) in Appeal Nos. E-782-783/2001, whereby the Tribunal by reversing the order passed by the Commissioner (Appeals) has held that M/s. Shakti Tubes Limited, respondent No. 1 herein and M/s. Shakti Steel Pipes Ltd., respondent No. 2 herein, are not one and the same but two separate units. 2. Respondent No. 1 is engaged in the manufacture of black pipes of different specifications which they cleared on payment of duty to M/s. Shakti Steel Pipes Ltd. respondent No. 2 herein, which is the sister concern of respondent No. 1. M/s. Shakti Steel Pipes Ltd. galvanised the black pipes and cleared the same without payment of duty inas much as the process of galvanisation does not amount to manufacture. This finding has been recorded treating both the units as two separate units. 3. Earlier, proceedings were initiated against the respondent No. 1 by issuing show cause notice on the ground that M/s. Shakti Tubes Ltd. and M/s. Shakti Steel Pipes are one and the same entity and the central excise Registration issued to M/s. Shakti Steel Pipes was proposed to be cancelled. The said show cause notice culminated into the order passed by the adjudicating authority cancelling Central Excise Registration issued to M/s. Shakti Steel Pipes Ltd. However, in appeal, Commissioner (Appeals) reversed the order of the adjudicating authority. Thereafter, revenue filed an appeal before the Tribunal which upheld the order of the Commissioner (Appeals) holding that both units are separate and independent units. Revenue accepted the decision of the Tribunal and did not challenge the same any further. 4. Later on, a show cause notice was again issued in the year 1999 raising demand of duty to the tune of Rs. 67,44,52,122 and also to show cause as to why their Central Excise Registration should not be revoked Tubes Limited should have paid the duty on the final product i.e. galvanised pipes instead of paying the duty on black pipes. 67,44,52,122 and also to show cause as to why their Central Excise Registration should not be revoked Tubes Limited should have paid the duty on the final product i.e. galvanised pipes instead of paying the duty on black pipes. Commissioner, who is the adjudicating authority, confirmed the demand raised in the show cause notice, which was later on reversed by the Tribunal by the order impugned before us by holding that both units are separate and independent. This is a finding of fact which does not call for any interference. Otherwise also, we are of the opinion that once the revenue has accepted the decision of the Tribunal in the earlier proceedings in which it was held that both units are separate and independent units, revenue is not justified in challenging the same subsequently to contend that both units are one and the same. 5. In view of the aforesaid position, these appeals are dismissed. Parties shall bear their own costs.