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Issues: Whether Modvat credit was admissible on HDPE bags used for packing finished products, having regard to the exclusion in the Explanation to Rule 57A(1) for bags or sacks made out of fabrics woven from strips or tapes of plastics.
Analysis: The exclusion was not confined to bags or sacks made out of textile fabric. Any woven material could amount to fabric for the purpose of the provision. Since the bags were made from material woven out of plastic strips and tapes, they fell within the exclusionary wording of the rule.
Conclusion: Modvat credit was not admissible on the HDPE bags and the denial of credit was upheld.