the purchase order the appellant has mentioned the supplier to comply with the specifications / requirements. So also, the purchase order shows the drawing number, description of the material (As per Annexure to Purchase Order No.00029). This proves that the appellant had submitted drawings of the items to their supplier. The said drawings are enclosed in the appeal paper book. These drawings show that the word ‘SALZER’ has to be etched on the moulds. The photographs of the imported goods have been placed before us. On perusal of these photographs, it is seen that the item bears the etching of the word ‘SALZER’. The appellant has submitted that they do not have any other company outside India. It can be strongly inferred that a product which has the name ‘SALZER’ etched on them is intended to be used by the said company only. The appellant is using these moulds for the manufacture of switches. From the drawings attached to the purchase order as well as the photographs, the probable inference that can be drawn is that the goods have been manufactured and imported only for the purpose of supplying to the appellant. Further, though the Chartered Engineer has stated that these are used and not new has not mentioned the details of wear and tear on the goods so as to arrive at such a conclusion. Therefore, the opinion of the Chartered Engineer that the moulds are ‘used’ and ‘not new’ does not seem to be factually proper. It requires to be mentioned that even though the etching of word ‘SALZER’ is prominent in the photographs, the Chartered Engineer has not mentioned anything about this in the report. Further, the report
