Narrow reading of consumable stores limits input tax credit to spare parts actually used up in manufacture.

"Consumable stores" under section 22(4) of the West Bengal Value Added Tax Act, 2003 was interpreted narrowly to mean stores or spare parts used in manufacture that are actually consumed, decayed, used up, or require replacement. The ordinary meaning of "consumable" was treated as deliberate legislative language, so not every spare part of plant and machinery used in production qualifies for input tax credit. It was also clarified that such goods need not lose identity or merge with the finished product to be covered. Authorities applying broader or differently worded statutes were distinguished on that basis.

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Issues: Whether spare parts of plant and machinery used in manufacturing taxable goods fall within the expression "consumable stores" under section 22(4) of the West Bengal Value Added Tax Act, 2003 for availing input tax credit.

Analysis: The expression "consumable stores" was held to comprise stores capable of being consumed in the course of manufacture, but not all spare parts of machinery. The adjective "consumable" was given its ordinary meaning, and the legislative choice of that word was treated as intentional. The relevant test was whether the goods are required for the purpose of manufacture and are of a kind that get decayed or used up and need replacement. It was also held that it is not necessary that such goods lose their identity or get mixed with the finished product. Authorities dealing with broader or differently worded statutes were distinguished on that basis.

Conclusion: Only those spare parts and stores of machinery which are decayed or used up and require replacement fall within "consumable stores" and qualify for input tax credit. Spare parts not answering that description do not.

Final Conclusion: The Tribunal's view was modified to confine the benefit to consumable machinery stores that are actually used up or require replacement, and the writ petitioner's challenge substantially failed.

Ratio Decidendi: Under section 22(4) of the West Bengal Value Added Tax Act, 2003, "consumable stores" means only such stores or spare parts used in manufacture as are consumed, decayed, or require replacement, and not every machinery spare part merely because it is used in production.

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