Packing machinery as capital goods qualifies when it is necessary for marketability and product protection.

Packing machinery used after manufacture for welding electrodes was treated as capital goods because packing was commercially necessary for marketability, protection of the goods, and identification of the manufacturer and product. Machinery not directly used in manufacture may still fall within Rule 57Q if it is necessary for the manufacturing process or to render the goods marketable. Applying that principle and supporting Tribunal authority, the packing machine and its spares were held eligible as capital goods, and credit was admissible.

---

---

Issues: Whether the packing machine and its spares used in packing welding electrodes were capital goods within the meaning of Rule 57Q.

Analysis: The machine was used in the packing of welding electrodes after manufacture, but packing was held to be commercially necessary for marketability, protection of the goods, and identification of the manufacturer and product. The decision also relied on the principle that machinery not directly used in manufacture may still qualify as capital goods if it is necessary for the manufacturing process or for rendering the goods marketable. The larger bench view in the cited Tribunal authority supported treating such machinery as within the scope of Rule 57Q.

Conclusion: The packing machine and its spares were capital goods and the credit was admissible.

---