Use in or in relation to manufacture broadly includes maintenance and fabrication supplies, permitting input credit for such items.

Items used for maintenance, repair, upkeep or fabrication of plant and machinery fall within the wide phrase "used in or in relation to manufacture" and therefore qualify for input credit; the article applies the settled principle that the phrase covers items used directly or indirectly in the manufacturing process whether or not incorporated in the final product, and concludes that welding electrodes, jointing sheets and similar supplies used in upkeep or fabrication are admissible for credit.

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Issues: Whether credit on items such as welding electrodes, jointing sheets and other items used for maintenance, repair, upkeep or fabrication of plant and machinery is admissible as being "used in or in relation to manufacture".

Analysis: The Court examined the scope of the expression "used in or in relation to manufacture" and applied settled legal principles holding that the phrase has wide import and includes items used in the process of manufacture whether directly or indirectly and whether contained in the final product or not. The Court considered prior authority which held that items used for maintenance, repair, upkeep or fabrication of plant and machinery are encompassed within items "used in" manufacture and therefore qualify for credit.

Conclusion: Credit on welding electrodes and similar items used for maintenance, repair, upkeep or fabrication of plant and machinery is admissible; the appeals are allowed in terms of the cited judgment.

Ratio Decidendi: The expression "used in or in relation to manufacture" is to be interpreted broadly to include all items used in the process of manufacture (directly or indirectly), including items used for maintenance, repair, upkeep or fabrication of plant and machinery, and such items qualify for input credit.

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