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Issues: Whether iron ore fines generated during screening of iron ore constitute exempted goods so as to attract Rule 6 of the Cenvat Credit Rules, 2004 and require reversal or payment of an amount on common input services credit.
Analysis: Iron ore fines arose as an unavoidable by-product or waste during screening and segregation of iron ore to make it fit for use in the furnace. They were not shown to be the result of any manufacturing process or a separate excisable commodity brought into existence by application of labour and process. Since the fines did not answer the character of manufactured exempted goods, the bar under Rule 6 did not apply merely because the fines were sold. The reasoning adopted aligned with the principle that waste or residue emerging in the course of handling or processing does not, by itself, attract reversal obligations under Rule 6 where no manufacture of exempted final products is involved.
Conclusion: Rule 6 of the Cenvat Credit Rules, 2004 was held inapplicable to the iron ore fines, and no amount at 5% or 6% of their value was payable; the Revenue's challenge failed.
Ratio Decidendi: Material that emerges only as waste, residue, or an unavoidable by-product during processing, without constituting manufacture of exempted goods, does not attract Rule 6 reversal obligations for common input service credit.