5. The above machines are not in this category inasmuch as they were used for a purpose subsequent to completion of manufacture [including packing] of cement. Hence capital goods credit would not be admissible to the first item. The decision of this Bench in Thiru Arooran Sugars Ltd. v. CCE, Tiruchirapalli cited by learned SDR supports this view. In that case, capital goods credit was held to be inadmissible to bag stacker which was a shelf arrangement in which bags filled with sugar duly stitched and labelled are stacked before removal from the factory. Bag stacking was found to be a post-manufactural activity.