Printing machine used for mandatory product marking treated as capital goods under Rule 57Q for credit eligibility.

A printing machine used to mark batch number, date of manufacture and maximum retail price on plastic containers of lubricating oil was treated as capital goods under Rule 57Q because the printing activity formed an integral part of making the product marketable. Although the containers were not manufactured by the assessee, the mandatory packing and marking requirements were held to be part of the manufacturing process for marketability. On that basis, the machine qualified for credit as eligible capital goods.

---

---

Issues: Whether the printing machine used for printing batch number, date of manufacture and maximum retail price on plastic containers of lubricating oil qualified as capital goods under Rule 57Q.

Analysis: The machine was used for printing particulars required for marketing the lubricating oil. The containers were not manufactured by the assessee, but packing and marking formed an integral part of the process by which the lubricating oil became marketable. Since goods must be marketable to attract duty and the printed particulars were mandatory, the printing activity was treated as part of the manufacturing process. On that basis, the machine was held to fall within the scope of capital goods under Rule 57Q.

Conclusion: The printing machine was eligible capital goods and the claim for credit succeeded.

---