R. Jayaraman, Member (T)

1. All the three appeals involve consideration of the same issue. Hence they were heard together and proposed to be dealt with by this common order.

2. The above appeals are against the orders of the Collector (Appeals) as indicated below:

3(1) The common issue in all the three appeals is whether Modvat Credit is admissible in respect of metallic wire netting of Phosphor Bronze and Dryer felt of woollen cloth, which are declared as inputs used in or in relation to the manufacture of paper.

3(2) The appellants filed declaration under Rule 57A declaring inter alia the aforesaid two items as inputs used in or in relation to the manufacture of paper. However, the Department issued a number of Show Cause Notices (reportedly within time limit prescribed) alleging that these items are part and parcel of their machinery and not correlated in relation with the manufacturing process. The Asstt. Collector confirmed the demands for reversal of Modvat Credit, holding that these items are not consumables but are used in removing water from the pulp and in drying as parts of machinery. On appeals before the Collector (Appeals), their appeals were rejected. The Collector