Factory premises include integral jetties and handling structures, supporting credit eligibility for manufacture-linked equipment parts.

For central excise purposes, a jetty owned, maintained and used exclusively by the assessee for moving raw material to the factory was treated as part of the factory premises under section 2(e), because factory includes land and structures integral to the manufacturing process and not merely the registered building area. The absence of formal departmental approval did not alter that position. On that basis, the parts of the unloading or moving arm installed on the jetty were regarded as eligible capital goods for credit under the relevant rules, since they formed part of the manufacture-linked handling arrangement. The appeal was allowed and the credit claim was held admissible.

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Issues: (i) Whether the jetty and the unloading arm installed on it formed part of the factory premises for the purposes of section 2(e); (ii) whether the parts of the moving arm qualified as capital goods so as to be eligible for credit under the relevant rules.

Issue (i): Whether the jetty and the unloading arm installed on it formed part of the factory premises for the purposes of section 2(e).

Analysis: The definition of factory extends to any premises, including the precincts thereof, where manufacture or a manufacturing process connected with production is carried on. The jetty was owned, maintained and operated by the appellant, formed part of the land owned by it, and was used exclusively for the movement of raw material to the factory. Registration or formal departmental approval of the premises was held not to be ative of factory status. Premises were understood broadly to include land and structures integral to the manufacturing set-up.

Conclusion: The jetty formed part of the factory premises and fell within section 2(e), in favour of the assessee.

Issue (ii): Whether the parts of the moving arm qualified as capital goods so as to be eligible for credit under the relevant rules.

Analysis: Since the jetty and the moving arm were part of the factory premises and were used in the manufacture-linked handling of raw material, the goods installed thereon were treated as eligible for the relevant credit scheme. The finding that the jetty was outside the factory was rejected, removing the basis for denying credit.

Conclusion: The parts of the moving arm were eligible for credit, in favour of the assessee.

Final Conclusion: The appeals were allowed because the jetty was treated as part of the factory premises and the credit claim on the moving arm parts was held admissible.

Ratio Decidendi: For central excise purposes, premises used for manufacturing activity include land and structures integral to the production process, and formal registration or departmental approval does not determine whether such premises constitute a factory.

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