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Issues: Whether printed and laminated aluminium foils, used for conversion into sachets for packing medicaments, qualified as "packaging materials" eligible for Modvat credit under Rule 57A and could be sent out under Rule 57F(2) for job work.
Analysis: The material received by the assessee was not general-purpose raw material, but printed and laminated aluminium foil specifically identifiable for packing the assessee's medicaments. Rule 57A covers packaging materials, and the expression is not confined to ready-to-use boxes, cartons, or sachets. The decisive test is whether the goods are identifiable and used as packaging material for the final product. The Board's clarification dealt with raw materials for making packaging articles and did not displace the wider meaning of packaging materials where the input itself is already recognisable as such. The conversion of foils into sachets on job work did not change their character for the purpose of Modvat eligibility, and the distinction drawn from cases involving plain plastic granules was accepted.
Conclusion: Printed and laminated aluminium foils were held to be packaging materials, Modvat credit was admissible, and removal under Rule 57F(2) for conversion into sachets did not defeat eligibility.