Inputs versus tools/appliances dispute: repeated use alone is insufficient, and a reasoned finding is required on exclusion.

Repeated use of goods in manufacture does not by itself establish that they are admissible inputs under Rule 57A, because such use may also indicate that they fall within the exclusion for tools, appliances or equipment. Where the composition and function of the goods are not clearly established, the authority must give a reasoned speaking finding on why the exclusion does or does not apply. The appellate order was therefore treated as inadequate, set aside, and the matter remanded for fresh consideration on whether Saggars were excluded articles or eligible inputs.

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Issues: Whether Saggars were inputs used in relation to the manufacture of glazed tiles or were excluded as tools, appliances or equipment under Rule 57A, and whether the appellate order required to be set aside for want of a speaking finding on the composition and function of the goods.

Analysis: The order under appeal treated Saggars as inputs mainly because they were used in relation to manufacture and could be used more than once. That reasoning was found insufficient, since repeated use does not by itself establish that the goods are inputs and may equally indicate that they fall within the exclusion for tools, appliances or equipment. The record did not clearly disclose the exact composition or function of Saggars, and the appellate authority had not explained why they were not excluded articles. The order was therefore regarded as non-speaking and inadequate for final determination.

Conclusion: The appellate order was set aside and the matter was remanded for a fresh speaking decision on whether Saggars were excluded tools, appliances or equipment or admissible inputs.

Final Conclusion: The dispute was not finally decided on merits and was sent back for reconsideration in accordance with law.

Ratio Decidendi: A finding that goods are inputs cannot rest only on their repeated use in manufacture; where their nature and function are not clearly established, a reasoned speaking order is necessary before determining whether they fall within the exclusion for tools, appliances or equipment.

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