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Issues: Whether the term "material" occurring in Rule 56A of the Central Excise Rules, 1944 refers only to raw material, and whether the question on that issue should be referred to the High Court.
Analysis: Rule 56A was examined as a whole, including the provisions dealing with provisional credit, waste arising in manufacture, stock of materials on discontinuance of credit, transfer of materials in process, and removal of partially processed material. Those provisions were treated as pointing to material received for use in manufacture in the sense of raw material. The interpretive principle of noscitur a sociis was also applied, since "material" occurs in the company of "components", supporting a meaning akin to raw material rather than machinery, bricks, or similar factory goods. On that basis, the question was treated as one involving a legal issue fit for reference.
Conclusion: The term "material" in Rule 56A was taken to refer to raw material, and the question of law was referred to the High Court for decision.
Final Conclusion: The reference application was disposed of by sending the surviving question of law to the High Court, while the other proposed questions were treated as not surviving for reference.
Ratio Decidendi: In construing Rule 56A, "material" is to be understood in the context of the rule's manufacturing scheme as referring to raw material and not to all goods used in a factory.