https://www.taxtmi.com/caselaws?id=81661 Exclusions under the Modvat scheme require strict construction, so coated abrasive paper used for polishing plywood was not treated as an excluded input merely because it was used in a machine. Tariff classification was relevant, and the goods had been classified under Heading 68 rather than as tools under Chapter 82. The paper was held to be a consumable item used in the manufacturing process, not machinery, equipment or a tool, and was therefore eligible for Modvat credit. The department's attempt to recharacterise it as machinery or equipment was rejected as inconsistent with the notice and appeal grounds and unsustainable on merits. en-us Mon, 30 Dec 1991 00:00:00 +0530 Tue, 28 Jun 2011 10:46:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=81661 Exclusions under the Modvat scheme require strict construction, so coated abrasive paper used for polishing plywood was not treated as an excluded input merely because it was used in a machine. Tariff classification was relevant, and the goods had been classified under Heading 68 rather than as tools under Chapter 82. The paper was held to be a consumable item used in the manufacturing process, not machinery, equipment or a tool, and was therefore eligible for Modvat credit. The department's attempt to recharacterise it as machinery or equipment was rejected as inconsistent with the notice and appeal grounds and unsustainable on merits. Case-Laws Central Excise Mon, 30 Dec 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=81661