Tool exclusion under Rule 57A applies to a mandrel used in filament coiling despite consumption in use.

Molybdenum wire used as a mandrel for coiling tungsten filament was treated as a tool under Rule 57A because it supported and shaped the coil during manufacture. Its consumption or destruction after use did not alter its character, since wear and exhaustion can be inherent in tools. The distinction between a consumable article and a tool was considered immaterial for the exclusion under the rule. On that basis, the mandrel was held to fall within the excluded category of tool and was not eligible as an input credit item.

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Issues: Whether molybdenum wire used as a mandrel for coiling tungsten filament was an input eligible for credit under Rule 57A, or an excluded tool.

Analysis: The mandrel was used to support and shape the coil and could not be formed without it. The fact that the mandrel was consumed or destroyed after use did not make it cease to be a tool, since wear and exhaustion are inherent in many tools and do not determine their character for the purposes of Rule 57A. The distinction between a consumable article and a tool was held to be immaterial to the exclusion under the rule, and the mandrel was found to perform the function of a tool rather than an appliance.

Conclusion: The mandrel fell within the excluded category of tool under Rule 57A and was not eligible as an input; the finding against the assessee was upheld.

Ratio Decidendi: For the purpose of Rule 57A, an item does not cease to be a tool merely because it is consumed or destroyed in use; if it functions as a tool in the manufacturing process, it falls within the exclusion.

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