Packing material is not a manufacturing input where it is used only after production, so exemption was unavailable.

Cello poly film used only to pack, protect and secure completed batteries was not an input, raw material or component part used in their manufacture, because it did not enter into the battery or contribute to its actual production. On that basis, exemption under Notification No. 201/79-CE was unavailable. The later amendment to the notification did not change this position, and the film remained outside the exemption. The request for Rule 56A credit was not decided on merits and was left to be pursued before the proper authority.

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Issues: Whether cello poly film used only for strip packing of batteries could be treated as an input, raw material, or component part used in the manufacture of batteries so as to qualify for exemption under Notification No. 201/79-CE.

Analysis: The exemption applied only where goods were used in the manufacture of the finished product as inputs, raw materials, or component parts. The film did not enter into the battery, did not react with or contribute to its creation, and was used only to pack, protect, and secure batteries after they were complete. Material that merely preserves or contains the finished product, without being directly related to its actual production, is not an input or raw material in manufacture. The subsequent amendment of the notification did not alter this position, and the film remained outside the ambit of the exemption. The request for Rule 56A credit was not adjudicated on merits and was left to be pursued before the proper authority.

Conclusion: Cello poly film was not an input, raw material, or component part used in the manufacture of batteries, and the exemption under Notification No. 201/79-CE was not available.

Final Conclusion: The appeal failed because packing material used only after completion of the batteries could not qualify for duty exemption on inputs used in manufacture.

Ratio Decidendi: A material used only to pack, protect, or secure a finished product, and not directly related to its actual production, is not an input or raw material used in the manufacture of that product for purposes of exemption.

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