Credit for capital goods parts depended on functional use as components, and ICAM systems qualified on the facts recorded.

ICAM systems were treated as eligible for credit where they qualified as parts, components or accessories of capital goods under Rule 57Q. The analysis relied on the departmental circular, which stated that exact classification of the parts was not decisive if the goods were used as parts, components or accessories with the capital goods. On the facts recorded, the item was treated as a component of the programmable controller, which formed part of the spinning machine, and credit was therefore admissible.

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Issues: Whether ICAM systems were eligible for credit as parts, components or accessories of capital goods under Rule 57Q.

Analysis: The appeal turned on whether the goods in question could be treated as parts, components or accessories of the capital goods covered by the rule. Reliance was placed on the departmental circular, which stated that the precise classification of the parts was not decisive and that credit would be admissible so long as the goods were parts, components or accessories used with the capital goods. On the facts recorded, the item was treated as a component of the programmable controller, which itself formed part of the spinning machine.

Conclusion: Credit was admissible and the Revenue's challenge failed.

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