Cenvat credit on structural steel used for EOT crane movement and factory operations upheld as input credit

Cenvat credit was found admissible on beams, angles, channels and similar goods used to fabricate structures for movement of EOT cranes and for other factory purposes, because the goods had a direct nexus with manufacturing activity within the factory premises. The roofing or shade function was treated as incidental, and in the absence of contrary evidence the appellate finding on user and eligibility was sustained. Credit was therefore allowed as inputs, not as capital goods.

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Issues: Whether Cenvat credit was admissible on beams, angles, channels and similar goods used for fabrication of structures for movement of EOT cranes and related factory use.

Analysis: The disputed goods were found to have been primarily used in the manufacture of structures for movement of EOT cranes within the factory and for transporting heavy inputs and finished goods. The appellate authority had recorded that the goods had a nexus with the manufacturing activity and were used in the factory premises, with the roofing/shade being only incidental. In the absence of contrary evidence, the finding that the goods qualified as input eligible for credit was sustained.

Conclusion: Credit was held admissible on the disputed goods as inputs, though not as capital goods, and the Revenue's challenge failed.

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