Full Judgment
2. The Commissioner(Appeals) ruled against the assessee appellants in this case on the observation that the cooling tower did not cause any change in substance or produce or process any goods. The main submission made in the appeal memorandum is that if the cooling tower is not used, no final goods can emerge. On this ground, the admissibility is sought.
3. In a number of cases, peripheral machinery which processes certain machinery or inputs and makes them ready for manufacture of final products had been held to be admissible. In the case of J.C.T.Electronics vs.CCE, Chandigarh (2000(124) E.L.T. 541) material cooling equipment was held as admissible input. The Tribunal in the case CCE vs.Sunil Synchem Ltd. (1990(107) E.L.T. 176) had held hat air conditionining plant being essential for completion of process of manufacture and integrally connected with ultimate manufacture of final products, would merit allowance. Following the law laid down in these judgments, the appeal is allowed with consequential relief, if any, as per law.