Capital goods treatment for plastic crates used in manufacturing upheld as eligible for Cenvat credit

Plastic crates used to move intermediate goods between stages of manufacture were treated as accessories used in the manufacturing process, bringing them within the definition of capital goods for Cenvat credit under Rule 2(b) of the Cenvat Credit Rules, 2002. The Court relied on an earlier Division Bench ruling that had accepted the Tribunal's view on the same issue, and treated the legal position as settled in favour of credit eligibility. On that basis, the crates were recognised as eligible for Cenvat credit as capital goods accessories, and the assessee succeeded on the substantial question of law.

---

---

Issues: Whether plastic crates used for moving intermediate goods between stages of manufacture qualify as accessories of machinery and therefore as capital goods eligible for Cenvat credit under Rule 2(b) of the Cenvat Credit Rules, 2002.

Analysis: The Court noted that the issue was already covered by an earlier Division Bench decision, which had accepted the view of the Tribunal that such crates functioned as accessories used in the manufacturing process for carrying intermediate products from one stage to another. On that basis, the legal position was treated as settled in favour of recognizing the goods as falling within the definition of capital goods for Cenvat credit purposes.

Conclusion: The plastic crates were held to be eligible for Cenvat credit as capital goods accessories, and the substantial question of law was answered in favour of the assessee and against the Revenue.

---