CENVAT credit on steel doors denied where they served only pharmaceutical premises compliance and were not inputs or capital goods.

Steel doors installed in medicine storage premises were held ineligible for CENVAT credit because they had no role in manufacture and did not satisfy the statutory description of inputs. They also could not be treated as capital goods, as they were not equipment or any specified category within the credit scheme. The requirement under Schedule M to the Drugs and Cosmetics Rules, 1945 for suitable or non-shedding doors in aseptic areas did not convert the doors into pollution control devices. Regulatory compliance with pharmaceutical premises norms was therefore distinct from eligibility for credit, and the denial of CENVAT credit was sustained.

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Issues: Whether steel doors used in storage premises for medicines were eligible for CENVAT credit as inputs or capital goods, including as a pollution control device.

Analysis: The steel doors were used in storerooms and had no role in the manufacturing process. They could not be treated as inputs for medicines. They also did not qualify as equipment or any specified category of capital goods, and the mere fact that Schedule M to the Drugs and Cosmetics Rules, 1945 requires non-shedding doors in aseptic areas did not make them pollution control devices. The regulatory requirement for suitable doors was held to be distinct from a pollution control device within the credit scheme.

Conclusion: The claim for CENVAT credit on steel doors was rejected, both as inputs and as capital goods.

Final Conclusion: The appeal failed and the denial of credit was sustained.

Ratio Decidendi: A product used only to satisfy pharmaceutical premises requirements, without a role in manufacture and without answering the statutory description of inputs or capital goods, does not qualify for CENVAT credit merely because it is required under drug-manufacturing norms.

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