Collector Of Central Excise vs Rohit Pulp And Paper Mills Ltd. on 6 February, 1985
In this connection the learned Consultant for the respondents has drawn our attention to the observations in the decision of this Tribunal in Appeal No. E/299/85(C) (Order No.C/314/85) : 1985 (21) ELT 901 in the case of Collector of Central Excise, Bhubaneshwar v. Tataghur Paper Mills. In paragraph 4 thereof it is observed - "a raw material is a material that is put into the manufacturing system to help in the formation of the finished product, here, the paper. We can see no logic in the arguments of the Assistant Collector who says, for example, that lime is used for manufacture of caustic soda and therefore is not a raw material for paper. But Caustic Soda is used in bleaching paper pulp. The lime is also used to make bleach liquor. The bleach liquor is again used in the manufacture of paper. The Assistant Collector's difficulty seems to be that between the lime and the paper these are intermediate products; that lime as such is not put into the system to manufacture paper. This is a wrong understanding of an input or a raw material. There is no authority to say that an input or raw material must go directly into the finished product. As long as it is consumed and utilised in a way that results or helps in the production or manufacture of the article in which the system is engaged, it is a raw material and is an input for that finished product."