Input credit for fibre glass filter mesh upheld where it was integral to piston casting and not excluded apparatus.

Fibre glass filter mesh used in piston casting was treated as an input used in relation to manufacture under Rule 57A because it was consumed in removing impurities from molten aluminium alloy and was integrally connected with the production process. It was not regarded as an independent machine, plant, equipment or apparatus within the Explanation's exclusion. The reasoning followed the larger Bench view that goods consumed in or closely connected with manufacture may qualify as inputs, and the mesh was therefore covered by input credit treatment.

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Issues: Whether fibre glass filter mesh used in the piston casting process was an input used in relation to the manufacture of pistons or was excluded as apparatus under Rule 57A of the Central Excise Rules.

Analysis: Rule 57A permits credit on inputs used in or in relation to manufacture, but its Explanation excludes machines, machinery, plant, equipment, apparatus, tools and appliances. The filter mesh was used to remove impurities from molten aluminium alloy in the casting process and was treated as functioning in relation to manufacture rather than as an independent apparatus. The reasoning followed the larger bench view that goods consumed in the manufacturing process or integrally connected with it may qualify as inputs notwithstanding their use in the process.

Conclusion: Fibre glass filter mesh was held to be an input used in relation to manufacture and not to fall within the excluded category of apparatus.

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