https://www.taxtmi.com/caselaws?id=50846 Ship-breaking is treated as manufacture, but Modvat credit is available only for goods used as inputs in that manufacturing activity. Fuel, oil, foodstuffs, bunkers and other ship stores brought on board for ship-breaking were held not to be inputs in the emergence of scrap, so credit was denied, except for the limited fuel and oil contained in the ship's engine and machinery. Penalty was not sustainable because the applicable Board circular was ambiguous, the respondents' view was arguable, and there was no finding of deliberate defiance of law. en-us Fri, 12 Oct 2001 00:00:00 +0530 Fri, 17 Sep 2010 16:39:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=50846 Ship-breaking is treated as manufacture, but Modvat credit is available only for goods used as inputs in that manufacturing activity. Fuel, oil, foodstuffs, bunkers and other ship stores brought on board for ship-breaking were held not to be inputs in the emergence of scrap, so credit was denied, except for the limited fuel and oil contained in the ship's engine and machinery. Penalty was not sustainable because the applicable Board circular was ambiguous, the respondents' view was arguable, and there was no finding of deliberate defiance of law. Case-Laws Central Excise Fri, 12 Oct 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=50846