4. Facts in brief giving rise to present appeal are that appellants, M/s Kisan Sahkari Chini Mills Ltd., having its unit at Sampurnanagar, District Lakhimpur Kheri, and Satha, District Aligarh (hereinafter referred to as the "Assessee 1 and Assessee 2" respectively and jointly as "Assessees") are engaged in manufacture of cane sugar and …