Modvat credit on packaging strips upheld where sealing strips were essential to make aseptic packaging marketable.

Polypropylene or polyethylene strips and pull tab strips used for sealing aseptic packaging rolls were treated as inputs eligible for Modvat credit because the rolls could not be converted into a marketable container without them. The Tribunal's conclusion that the strips were used in or in relation to manufacture rested on factual findings supported by precedent, and those findings were accepted as such. The Revenue's challenge was rejected, and the strips were recognised as inputs for Modvat credit purposes.

---

---

Issues: Whether polypropylene or polyethylene strips and pull tab strips are inputs eligible for Modvat credit in relation to manufacture of aseptic packaging.

Analysis: The packaging rolls could not be converted into a marketable container without the use of the strips used for sealing. The Tribunal's view that the strips were used in or in relation to manufacture was based on factual findings supported by precedent. Those findings were treated as findings of fact and no basis was found to call for a statement of the case.

Conclusion: The strips were inputs for the purposes of Modvat credit, and the Revenue's application was rejected.

---