Inclusive definition of "input" read broadly under CENVAT Credit Rules, with individual credit entitlement left on facts.

The inclusive definition of "input" in Rule 2(g) of the CENVAT Credit Rules, 2002 was construed as enlarging the term beyond the six items specifically listed, because the word "include" in a statutory definition ordinarily extends meaning rather than limits it unless context shows otherwise. The Court relied on settled precedent treating inclusive language as expansive and answered the referred legal question in favour of a broader reading for the assessee. Actual entitlement to CENVAT credit in individual matters was left open to be determined on the relevant factual matrix by the appropriate bench.

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Issues: Whether the definition of "input" in Rule 2(g) of the CENVAT Credit Rules, 2002 is to be understood as an inclusive definition enlarging the scope of the term beyond the items specifically mentioned therein.

Analysis: The reference was answered by applying the settled principle that the word "include" in a statutory definition ordinarily enlarges the meaning of the defined expression rather than restricting it. The Court treated the answer as flowing from the reference order and from earlier three-Judge Bench authority stating that inclusive language is used by way of extension. The question of the assessee's actual entitlement to CENVAT credit in individual cases was left to be decided on the factual matrix by the appropriate bench.

Conclusion: The definition of "input" in Rule 2(g) is to be read as enlarging the term beyond the six items specifically mentioned, in favour of the assessee.

Final Conclusion: The referred legal question on the scope of "input" was answered by adopting an expansive construction of the inclusive definition, while leaving factual entitlement issues open for decision in the individual matters.

Ratio Decidendi: The word "include" in a statutory definition ordinarily enlarges the scope of the defined term and is not restrictive unless the context clearly indicates otherwise.

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