Ramming mass as an eligible input under Modvat rules supports credit where the item is used in manufacturing.

Ramming mass was treated as an "input" under Rule 57A for Modvat purposes, because material used in the manufacturing process cannot be denied credit merely by describing it as part of the machinery. Applying the directly relevant High Court ruling, the tribunal held that the item fell within the scope of eligible inputs rather than the machinery exclusion. On that basis, Modvat Credit was admissible, the appeals succeeded, and the cross-objections did not survive.

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Issues: Whether ramming mass is an "input" under Rule 57A for the purpose of Modvat Credit, or whether it is part of the machinery so as to deny such credit.

Analysis: The referred question was answered by following the only directly applicable High Court ruling on the point. On that basis, ramming mass was treated as falling within the expression "input" for Rule 57A purposes, and not as machinery excluded from Modvat eligibility.

Conclusion: Ramming mass is an "input" within Rule 57A and Modvat Credit is admissible.

Final Conclusion: The appeals succeeded and the respondent's cross-objections did not survive in light of the ruling that ramming mass qualifies for Modvat Credit as an input.

Ratio Decidendi: Where a material used in the manufacturing process is treated as an input under Rule 57A, Modvat Credit cannot be denied merely by characterising it as part of the machinery.

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