Modvat credit eligibility on inputs and machinery parts upheld for X-ray materials, steel shots, carbon dioxide and refractories.

Modvat credit was treated as admissible on X-ray films, flow guide developers, flow guide dye penetrants, steel shots, graphite stopper heads, carbon dioxide and refractories because earlier Tribunal decisions had already recognised these items as eligible inputs. X-ray films and the related developers and dye penetrants were regarded as inputs used for X-ray purposes and goods used in or in relation to manufacture; steel shots were accepted as inputs; graphite stopper heads were treated as machinery parts and not excluded under Rule 57A; and carbon dioxide and refractories were also covered by prior rulings. Credit was therefore allowed on all disputed items.

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Issues: Whether Modvat credit was admissible on X-ray films, flow guide developers, flow guide dye penetrants, steel shots, graphite stopper heads, carbon dioxide and refractories.

Analysis: The items were held to be eligible inputs for Modvat credit on the basis of earlier Tribunal decisions. X-ray films were recognised as eligible inputs, and the associated flow guide developers and dye penetrants were treated as inputs used for X-ray purposes and as goods used in or in relation to the manufacture of the final product. Steel shots were accepted as inputs. Graphite stopper heads were treated as part of machinery and not falling within the excluded category under Rule 57A. Carbon dioxide and refractories were also covered by prior decisions allowing credit.

Conclusion: Modvat credit was admissible on all the disputed items.

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