Capital goods credit for thermocouple tips used in industrial furnaces upheld as eligible components and accessories.

Thermocouple Tips used in industrial furnaces were treated as eligible capital goods credit under Rule 57Q, even though Heading 90.33 was not specifically mentioned against the relevant entry in the table. The reasoning accepted that the tips qualified as components, spares or accessories of goods covered by Serial Nos. 1 to 4, and industrial furnaces fell within Serial No. 3. On that basis, credit was correctly allowed under Serial No. 5 of the table appended to Rule 57Q, supporting the broader inclusion of functional furnace parts within the credit scheme.

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Issues: Whether Thermocouple Tips, though not specifically mentioned against the relevant heading in the table appended to Rule 57Q, were eligible for credit as capital goods or as components, spares and accessories of goods covered by the table.

Analysis: The table appended to Rule 57Q did not specifically mention Heading 90.33 against the entry relied upon by the department. However, the goods had been allowed credit by the lower authorities under the entry covering components, spares and accessories of goods specified against Serial Nos. 1 to 4. Industrial furnaces were covered under Serial No. 3, and the Thermocouple Tips were used in such furnaces. The reasoning therefore supported treating them as eligible components, spares and accessories for the purposes of Rule 57Q.

Conclusion: The credit was rightly allowed under Serial No. 5 of the table appended to Rule 57Q, and the department's appeal failed.

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