Exemption for integrated steel plants extends to ore concentrate as part of the same input under the notification.

Iron ore and ore concentrate were treated as the same commercial input for exemption under Notification No. 13/2000-C.E. applying to integrated steel plants. The notification was read in light of the circular dated 26-2-2003, which clarified that "ore" included ore concentrate and avoided an anomalous distinction between mined ore and processed concentrate used in steel manufacture. The interpretation followed the earlier decision on the same exemption framework, and the Tribunal's view supporting the assessee was left undisturbed. The Tribunal's adverse remarks against the Commissionerate were found unnecessary and were expunged.

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Issues: Whether iron ore and ore concentrate are distinct commercial commodities for the purpose of exemption under Notification No. 13/2000-C.E. applicable to integrated steel plants.

Analysis: The exemption notification treated an integrated steel plant as one manufacturing steel from iron ore as the starting material. The circular dated 26-2-2003 clarified that the expression "ore" in the notification included ore concentrate, removing the practical anomaly that arose because iron ore is mined and processed into ore concentrate before use. The Tribunal's view was consistent with the earlier decision on the same exemption framework, and the interpretation adopted by it required no interference. The observations made by the Tribunal against the functioning of the Commissionerate were, however, found unnecessary.

Conclusion: Iron ore and ore concentrate were not to be treated differently for the exemption, and the assessee remained entitled to the benefit under the notification. The adverse remarks of the Tribunal were expunged.

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