Input exemption under excise notification applies to lead sheets, while headers used in manufacture remain outside the benefit.

The exemption under Notification No. 217/86-C.E. applies only to inputs and excludes machines, machinery, plant, equipment, apparatus, tools and appliances used in manufacture or processing. On the admitted facts, lead sheets qualified as inputs and remained eligible for the notification. Headers, whether attached to lead or aluminium sheets, were not inputs and therefore did not qualify for the exemption. The operative distinction was between the exempt input material and the non-qualifying component used in the manufacturing process.

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Issues: Whether lead anode sheets and headers were entitled to the benefit of Notification No. 217/86-C.E. dated 2nd April, 1986.

Analysis: The notification grants exemption only to inputs and specifically excludes machines, machinery, plant, equipment, apparatus, tools and appliances used in manufacturing or processing, or in relation to a final product, from the meaning of inputs. On the admitted position, sheets constituted inputs. Headers, whether attached to lead or aluminium sheets, did not fall within the category of inputs and therefore could not receive the exemption. The position was different for the sheets themselves, which remained eligible for the notification.

Conclusion: The benefit of the notification was available to the lead sheets, but not to the headers.

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