Input credit eligibility for steel structures depends on whether they support machinery or serve only civil construction.

Credit on beams, joists, steel structures, casings, floor beams and bracing could not be denied without a clear factual finding on whether the items were used merely for civil construction or as supporting structures essential to the plant's functioning. The record did not show whether they supported machinery at a specific plant position or formed part of construction materials for civil work, so eligibility could not be finally determined. The denial of credit was therefore not sustainable on the existing findings, and the matter required fresh factual examination by the Original Authority.

---

---

Issues: Whether the rejection of the declaration and denial of credit on beams, joists, steel structures, casings, floor beams and bracing was sustainable without a clear factual finding on whether those items were used as supporting structures essential for the plant.

Analysis: The competing lines of authority distinguished between steel structures used merely for civil construction and structural materials used to support machinery so that the plant could function in conjunction with other components. On the facts recorded, the lower authorities had not given a finding whether the items were actually used to support the machinery at a particular position in the plant or whether they were used along with construction materials for civil work. In the absence of such factual determination, a final conclusion on eligibility could not be reached.

Conclusion: The denial of credit could not be sustained on the existing findings, and the matter required fresh factual examination by the Original Authority.

---