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TMI Blog2000 (11) TMI 153X X X X Extracts X X X X X X X X Extracts X X X X ..... ioner involve the use of kraft papers which are used for interleaving the strips in order to prevent the strips getting into direct contact, as that would result in friction which would in turn result in defects and also would be potential points for corrosion. The interleaving paper also serves as an oil absorvant thus improving the surface and brightness of the steel coils and sheets. Unless suc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... processing or any goods or bringing about any change in any substance or in relation to the manufacture of the final products; (ii) packaging materials in respect of which any exemption to the extent of the duty of excise payable on the value of the packaging materials is being availed of for packaging any final products; (iii) packaging materials, the cost of which is not included or had not b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tainless steel sheets. We find it difficult to appreciate or approve such a view. The paper used here is neither an apparatus nor a tool. It is certainly not an appliance, equipment, plant, machinery or machine. The category of machines and similar equipments referred to in sub-clause (i) in clause (b) of the explanation are things which are not themselves consumed in the process of manufacture. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is, therefore, evident that the kraft paper which the assessee had purchased by paying duty has been used by it in relation to the manufacture of the final product and that it has been used in the process of manufacture at every stage of coiling and recoiling and that it is not an item which is excluded from the category of inputs under the explanation below the proviso to Rule 57A. 4. Our attent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ft paper is used in relation to the manufacture within the factory of the assessee and is essential for the purpose of maintaining the quality of the product. The question referred to us as to whether the kraft paper can be regarded as not used as input in relation to stainless steel products for the purpose of Rule 57A is answered in favour of the assessee and against the revenue. The other quest ..... X X X X Extracts X X X X X X X X Extracts X X X X
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