Cenvat credit on fabrication inputs upheld where evidence showed use in manufacturing capital goods under Chapter Heading 84.

Cenvat credit on inputs such as plates, angles, channels, sheets and welding rods was held admissible where the record, including documents, photographs and a Chartered Engineer's certificate, showed use in manufacturing rotary kiln, rotary cooler, pollution control equipment, conveyors and after-burn chambers classifiable under Chapter Heading 84. The factual finding that the inputs were deployed for manufacture of capital goods was supported by evidence, and no infirmity in that appreciation was shown. On that basis, the Revenue's challenge failed and the entitlement to credit was upheld.

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Issues: Whether Cenvat credit on inputs such as plates, angles, channels, sheets and welding rods was admissible when the goods were used in the manufacture of rotary kiln, rotary cooler, pollution control equipment, conveyors and after-burn chambers falling under Chapter Heading 84.

Analysis: The disputed order was based on documents, records, photographs and a Chartered Engineer's certificate showing that the goods were used in the manufacture of capital goods. The appellate finding that the goods were deployed for such manufacture was supported by the record, and no infirmity in that factual appreciation was shown to justify interference.

Conclusion: Cenvat credit was admissible, and the Revenue's challenge failed.

Final Conclusion: The appeal was rejected after upholding the entitlement to Cenvat credit on the disputed inputs used in the manufacture of capital goods.

Ratio Decidendi: Where the record supports a factual finding that inputs were used in the manufacture of capital goods, Cenvat credit cannot be denied merely on a challenge to the manner in which the evidence was appreciated.

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