Liberal construction of capital goods definition supports Cenvat credit on structural items, components, accessories and storage tanks.

Cenvat/Modvat credit was treated as available on structural items, components, accessories and storage tanks used in manufacturing premises when the capital goods definition was construed liberally. The Court followed its earlier ruling on the same issue and regarded the later express inclusion of storage tanks as classificatory, supporting credit even for the earlier period. On that reasoning, the Revenue's challenge was found to raise no substantial question of law, and the assessee's credit claim was upheld.

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Issues: Whether the assessee was entitled to Cenvat/Modvat credit on structural items, components, accessories and storage tanks as capital goods, and whether any interference was warranted in the Revenue's appeal.

Analysis: The Court followed its earlier decision on the same question and accepted that the definition of capital goods had to be applied liberally to items used as components, accessories, and parts of installed machinery, including storage tanks used in the manufacturing premises. The reasoning treated the later specific inclusion of storage tanks in the definition as classificatory in nature and therefore supportive of credit even for the earlier period. On that basis, the Court found no merit in the Revenue's challenge and held that no substantial question of law arose.

Conclusion: The assessee was entitled to the credit claimed, and the Revenue's appeal failed.

Final Conclusion: The impugned order granting Cenvat/Modvat credit was affirmed, and the appeal stood dismissed.

Ratio Decidendi: Items forming parts, components, accessories, or integral structural elements of manufacturing machinery, including storage tanks, may qualify for credit as capital goods where the statutory definition is construed liberally in light of the manufacturing use.

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