Job-work goods under Cenvat Credit Rules treated as pari materia with earlier precedent, supporting the assessee.

Goods manufactured on a job-work basis under Rule 4(5)(a) of the Cenvat Credit Rules were treated as covered by the earlier precedent relating to the corresponding erstwhile rule. The Tribunal noted that the goods were received under job-work challans, processed and returned through the same procedure, and the principal manufacturer used the assembled goods in manufacturing final products on payment of duty. On that basis, it held the two provisions to be pari materia and applied the earlier ruling to the present facts. The assessee succeeded, and the revenue's objection to applying the precedent failed.

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Issues: Whether goods manufactured on job-work basis under Rule 4(5)(a) of the Cenvat Credit Rules were liable to be assessed differently, and whether the benefit of the earlier precedent applied to the assessee.

Analysis: The goods were received under job-work challans, processed and returned under the same procedure, and the principal manufacturer used the assembled goods for manufacture of its final products on payment of duty. The dispute turned on whether the earlier ruling dealing with the corresponding erstwhile rule could be treated as applicable. The Tribunal accepted that the two provisions were pari materia and that the earlier precedent governing job-work clearances correctly covered the present facts.

Conclusion: The issue was decided in favour of the assessee, and the revenue's objection to application of the precedent failed.

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