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TMI Blog1994 (11) TMI 239X X X X Extracts X X X X X X X X Extracts X X X X ..... lves and elements in terms of Rule 57A of Central Excise Rules, 1944 and a further issue relating to the grant of permission under Rule 57F(2) for sending out Ethyl Cellulose for conversion and manufacture of dipping compound. 3. Shri Jeyaseelan, the learned DR adopted the reasoning in the order of the original authority and contended that dipping compound is not an input in the manufacture of delivery valves and elements. It was urged that the manufacture of delivery valves and elements [are] complete even before coating of the dipping compound and the coating with the dipping compound is done only for the purpose of protecting the goods in transit and, therefore, it is not an input in the manufacture of delivery valves. It was further u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ble High Court of Madras. It was further urged that the Tribunal in the case of M/s. Addison Co. v. CCE reported in 1990 (48) E.L.T. 281 has taken the view that anti-rust and anti-corrosion oil applied to the goods in the last stage of manufacture as a preventive measure to prevent rusting and corrosion of the goods is input within the meaning of Rule 57A. It was further urged that apart from dipping serves the purpose of a protected cover to maintain lubrication to the required degree, it also prevents corrosion. The learned Counsel further urged that the cost of dipping process is also included in the cost of final product. 5. We have considered the submissions made before us. The learned Collector (Appeals) dealing with the issue i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng of goods would be commercially inexpedient, articles required in that process would fall within the expression `in the manufacture of goods ". From the said view point and from the Asstt. Collector s own findings and observations in the impugned order, namely that the dipping compound provides the protective cover for element and delivery valves and also that without the said coating, it will be commercially inexpedient to sell the products, the Ethyl Cellulose, which goes into the manufacture of dipping compound has to be considered as an input. Further, Rule 57A, while explaining the scope of the word input, has mentioned the types of goods to be considered as inputs in the explanation provided in the said rule. There are certain types ..... X X X X Extracts X X X X X X X X Extracts X X X X
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