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Issues: Whether goods used for lining, maintenance, or replacement in furnaces, ladles, and allied machinery qualified as inputs used in or in relation to the manufacture of the finished product for Modvat credit under Rule 57A, and whether any question of law arose for reference.
Analysis: The distinction drawn was between materials that participate directly in the process of manufacture and materials used for maintenance of machinery or for making implements functional. Inputs used only to maintain machinery or as replacement parts were held not to be used in or in relation to the manufacture of the finished product. The materials in question were treated as falling in that category, since they served maintenance or functional purposes rather than entering the manufacturing stream.
Conclusion: The goods were not eligible for Modvat credit. No question of law arose for reference.