CENVAT credit on steel items used for plant installation and maintenance remains available despite earth-embedded resulting structures.

CENVAT credit is admissible on duty-paid MS plates, angles, channels, beams and similar iron and steel items used to install, repair or maintain factory plant and machinery. The notes state that denying credit merely because structural steel items fall under Chapter 72 is unsustainable following the overruling of the Larger Bench view in Vandana Global. Iron and steel items used in relation to manufacture, including for fabrication and maintenance of capital goods, qualify as inputs; embedding a resulting structure to earth does not by itself negate eligibility. The stated conclusion supports credit eligibility for the disputed items.

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Issues: Whether CENVAT credit is admissible on duty-paid MS plates, angles, channels, beams and similar iron and steel items used for installation, repair and maintenance of plant and machinery in the factory.

Analysis: The denial rested on the premise that structural steel items falling under Chapter 72 could not qualify as inputs even when used for fabrication, repair or maintenance of capital goods. That premise was unsustainable because the Larger Bench view in Vandana Global had been overruled. The applicable decisions recognise that iron and steel items used in relation to manufacture, including for fabrication and maintenance of plant and machinery, qualify for credit; the fact that a resultant structure is embedded to earth does not by itself defeat eligibility. The same issue arising from the same order-in-appeal had also been decided in the assessee's favour.

Conclusion: CENVAT credit on the disputed iron and steel items used for installation, repair and maintenance of plant and machinery is admissible, in favour of the assessee.

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