Classification of Structural Steel as inputs or capital goods rejected for relitigation where precedent resolves entitlement to CENVAT credit.

Whether structural steel items qualify as inputs for CENVAT credit or as capital goods was the core issue; non-speaking tribunal orders ordinarily require setting aside and remittal for reasoned decisions, but the coordinate bench in Vandana Global already adjudicated the same legal question applying prior authorities and a clarificatory amendment to the CENVAT Credit Rules. Because the appeals raise an identical legal point covered by that precedent, remittal would relitigate a settled issue; consequently the appeals were dismissed and remittal to the tribunal refused, disposing the appeals per the coordinate decision.

---

---

Issues: Whether the appeals by the revenue seeking reconsideration of the classification of structural steel items as inputs or capital goods should be remitted to the Tribunal for fresh decision or dismissed in view of a prior Division Bench decision on the same question.

Analysis: The impugned orders are non-speaking in form; ordinarily a non-speaking order that impedes judicial review requires setting aside and remittal for a reasoned decision. However, the substantive question concerning whether structural steel items constitute inputs (and hence eligible for CENVAT credit) or capital goods has been judicially determined by a Coordinate Bench in Vandana Global, which applied earlier High Court authorities and a clarificatory amendment to the CENVAT Credit Rules. The appeals before the Court raise the same legal issue that is directly covered by that binding earlier decision, so remittal would only result in re-litigation of an already-settled question.

Conclusion: The appeals are dismissed in view of the prior decision; remittal to the Tribunal is refused and the appeals are disposed of in the same terms as the Coordinate Bench decision.

---