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Issues: (i) Whether credit was admissible on inputs used in fabrication of the captive power plant set up adjacent to the factory for exclusive supply of power to the manufacturing unit; (ii) Whether credit was admissible on angles, channels, plates and similar items used for fabrication of capital goods and on dumper parts used for raw material handling within the plant.
Issue (i): Whether credit was admissible on inputs used in fabrication of the captive power plant set up adjacent to the factory for exclusive supply of power to the manufacturing unit.
Analysis: The credit was denied on the premise that the power plant was outside the factory and that the items used in its fabrication were not eligible inputs. The record showed that the power plant was meant exclusively for the appellants' factory and the same factual pattern had already been accepted in the appellants' own earlier matter, where credit on inputs used for fabrication of the captive power plant was allowed.
Conclusion: Credit on inputs used in fabrication of the captive power plant was held admissible in favour of the assessee.
Issue (ii): Whether credit was admissible on angles, channels, plates and similar items used for fabrication of capital goods and on dumper parts used for raw material handling within the plant.
Analysis: The disputed items were used for fabrication of machinery and other capital goods necessary for the plant, and the dumpers were used within the factory for movement of raw material. Applying the settled principle that components and parts which are essential to the functioning of plant and machinery form part of the manufacturing apparatus, the Tribunal treated these items as eligible for credit.
Conclusion: Credit on the said fabrication materials and dumper parts was held admissible in favour of the assessee.
Final Conclusion: The impugned orders were set aside and the appeals were allowed, with consequential relief to the assessees.
Ratio Decidendi: Inputs and materials used in the fabrication of plant, machinery, and integral components of the manufacturing setup, including captive power plant infrastructure and in-plant material handling equipment, are eligible for credit when they form an essential part of the manufacturing process.