CENVAT credit on site-delivered inputs remains admissible where duty-paid goods are used in manufacturing the final product.

CENVAT credit was held admissible on MS platforms used in manufacturing weigh bridges where duty-paid inputs were sent directly to the customer site for erection and commissioning. The earlier consistent view in the assessee's own proceedings had already accepted that credit cannot be denied merely because the goods were not physically received in the factory, provided they were used in manufacture of the final duty-paid product. The later authority was required to follow the binding earlier decisions on the same question of fact and law, so the contrary demand was unsustainable and the credit claim remained allowable.

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Issues: Whether CENVAT credit on MS platforms used in the manufacture of weigh bridges was admissible when the goods were not received in the factory but were supplied directly to the customer site for erection and commissioning.

Analysis: The dispute had already been decided in the assessee's own earlier proceedings and in connected orders for similar periods. Those orders held that inputs sent directly to the site of the project, and used in the manufacture of the final product on which duty was paid, remained eligible for credit and that credit could not be denied merely because the goods were not physically received in the factory. The later adjudicating authority was bound to follow the earlier decisions of the Tribunal and the appellate authority on the same question of fact and law. In view of the identical issue, the earlier consistent findings, and the principle that authorities lower in the hierarchy must give effect to superior and coordinate decisions, the contrary demand could not be sustained.

Conclusion: CENVAT credit on the MS platforms was admissible, and the demand raised by denying such credit was unsustainable.

Final Conclusion: The writ petition succeeded and the impugned order was quashed, leaving the assessee entitled to the credit claimed on the MS platforms.

Ratio Decidendi: Credit cannot be denied merely because duty-paid inputs are delivered directly to the project site instead of the factory, where they are used in the manufacture of a final product on which duty is paid, and lower authorities must follow the consistent binding view already taken on the same issue.

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