Rule 57A input credit turns on factual use and characteristics; machinery exclusion does not automatically cover machinery parts.

Rule 57A allows credit for goods used in or in relation to manufacture, but excludes machinery, plant and appliances. Whether a particular item falls within the exclusion depends on its characteristics and its actual use in the manufacturing process, making the issue factual rather than one of law. The specific exclusion of machinery does not automatically bar parts of machinery from the rule's benefit. On that basis, no substantial question of law arose, and the reference application was rejected, leaving the assessee's admissibility claim undisturbed.

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Issues: Whether the reference application raised any question of law in relation to admissibility of inputs under Rule 57A, and whether the exclusion of machinery, plant and appliances covered the items in question.

Analysis: Rule 57A permits goods used in or in relation to the manufacture of the final product, while specifically excluding machinery, plant and appliances. Whether a particular article falls within the excluded category depends on its characteristics and its actual use in the manufacturing process. That determination is factual in nature. The order also noted that the specific exclusion of machinery does not, by itself, bar parts of machinery from the benefit of the rule.

Conclusion: No substantial question of law arose. The reference application was rejected, and the assessee's position on admissibility was left undisturbed.

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