Proforma credit on packing material under Notification No. 201/79 extended to corrugated boxes used for duty-paid goods.

Notification No. 201/79 was interpreted to give the term "input" a wide scope, extending beyond raw materials or components forming part of the finished product. Packing materials used to secure and preserve manufactured goods, including corrugated boxes, were treated as eligible inputs for proforma credit where duty had been paid. The later amending Notification No. 105/82 was noted as narrowing the scope prospectively, which supported the conclusion that the unamended 1979 notification covered such packing materials. The note therefore states that packing-related articles could qualify for exemption-linked credit under the original notification.

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Issues: Whether corrugated boxes used for packing duty-paid goods falling under Tariff Item 68 could be treated as inputs for the purpose of proforma credit under Notification No. 201/79 dated 04.06.1979.

Analysis: The Tribunal applied its earlier view that the expression "input" in Notification No. 201/79 was of wide scope and was not confined to raw materials or components forming part of the finished product. Packing materials used for securing and preserving the manufactured goods were treated as eligible inputs under the notification. The later amending Notification No. 105/82 was noted as having narrowed the scope prospectively, which reinforced the position that the unamended 1979 notification covered such packing material. The Tribunal also followed its earlier decisions treating packing-related articles as inputs for similar exemption purposes.

Conclusion: The corrugated boxes used for packing were eligible inputs under Notification No. 201/79, and the assessee was entitled to proforma credit.

Final Conclusion: The appeal succeeded and the assessee obtained consequential relief.

Ratio Decidendi: Under Notification No. 201/79, the term "input" includes duty-paid packing material used in relation to the manufactured goods, unless the notification is subsequently narrowed by amendment.

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