( 1 ) THE point involved in this writ petition is the construction of Rule 57a of the Central Excise Rules, 1944 (referred to as the Rules ). Rule 57a allows for credit of duty paid on excisable goods used as inputs on the manufactured item. The question is whether dolopatch mix, Magnesite Peas and ramming mass is an input of steel ingots.

( 2 ) THE word 'inputs' has been defined in the explanation to Rule 57a. The explanation reads as follows :-"explanation - For the purpose of this rule "inputs" includes - (a) inputs which are manufactured and used within the factory of production or in relation to the manufacture of final products; and (b) paints and packaging material, but does not include - (i) Machines, machinery, plant, equipment, apparatus, tools or appliances used for producing or processing of any goods or for bringing about any change in any substance in 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 packaging materials is being availed of for packaging any final products; (iii) packaging materials the cost of which is not includ