Judgment :- The Order of the Court is as follows :- Stainless steel strips and coils manufactured by the petitioner involve the use of kraft papers which are used for interleaving the strips in order to prevent the strips getting into direct contact, as that would result in friction which would in turn result in defects and also would be potential points for corrosion. The interleaving paper also serves as an oil absorvant thus improving the surface and brightness of the steel coils and sheets. Unless such kraft paper is used for interleaving, the final products cannot be defect-free. The assessee therefore claimed that the interleaving paper is an input and the duty paid on the purchase of that interleaving kraft paper is to be considered under Rule 57A of the Central Excise Rules. 2.Rule 57A as it then stood in the explanation under the proviso set out an inclusive definition of inputs with an explanation which reads as under : "For the purposes of this rule "inputs" includes - (a)inputs which are manufactured and used within the factory of production in or, in relation to, the manufacture of final products, and (b)paints and packaging materials, but does not include (i)machines, machinery, plant, equipment, apparatus, tools or appliances used for producing or processing or any goods or bringing about any change in any substance 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 the packaging materials is being availed of for packaging any final products; (iii)packaging materials, the cost of which is not included or had not been included during the preceding financial year in the assessable value of the final products under Section 4 of the Act;(iv)cylinders for packing gases; (or) (v)plywood for tea chests; The kraft paper is clearly an item which is used within the factory of production in relation to the manufacture of the final product, namely, stainless steel coils and stainless steel, sheets and would thus be an input for the purpose of Rule 57A. Such usage of kraft paper in the factory of production in relation to the manufacture of final product is not excluded from the category of inputs by reason of anything contained in clauses 1 to 5 in the explanation. Such usage of kraft paper in the factory of production in relation to the manufacture of final product is not excluded from the category of inputs by reason of anything contained in clauses 1 to 5 in the explanation. The Tribunal had gone to the extent of holding that the kraft paper is in the nature of equipment or appliance used in the manufacture of stainless steel sheets. We find it difficult to appreciate or approve such a view. The paper used here is neither an apparatus nor a tool. It is certainly not an appliance, equipment, plant, machinery or machine. The category of machines and similar equipments referred to in sub-clause (i) in clause (b) of the explanation are things which are not themselves consumed in the process of manufacture. It is not the case of the Revenue that the manufacturer had availed any exemption for the duty of excise payable on the value of the paper by regarding the same as packaging material. The finding recorded by the Collector of Central Excise is that this paper is used in the process of manufacture. In the course of his order, the Collector has stated that every coiling operation in this process flows through various processing units with interleaving paper and that the interleaving paper is taken out in the next processing during uncoiling and further that the coils undergo generally six to seven uncoiling and recoiling operations depending on the grade and gauge of stainless steel products and the process cycle it has undergone. Every process involves one coiling and one recoiling. 3.It is, therefore, evident that the kraft paper which the assessee had purchased by paying duty has been used by it in relation to the manufacture of the final product and that it has been used in the process of manufacture at every stage of coiling and recoiling and that it is not an item which is excluded from the category of inputs under the explanation below the proviso to Rule 57A. 4.Our attention was also drawn by the Counsel to the decision of the Supreme Court in the case of Collector, Central Excise v. Eastend Paper Industries Ltd., wherein the court considered the question as to whether the kraft papers can be regarded as raw material and component part of wrapped paper entitled to exemption under Notification No. 18A/83-C.E. The court after holding that in order to claim the benefit of the notification the assessee had to establish that the wrapping papers were consumed or utilised as component parts or raw material for the final products held that anything required to make the goods marketable must form part of the manufacture and any raw material or materials used for the same would be component for the end-product. 5.In this case, the kraft paper is used in relation to the manufacture within the factory of the assessee and is essential for the purpose of maintaining the quality of the product. The question referred to us as to whether the kraft paper can be regarded as not used as input in relation to stainless steel products for the purpose of Rule 57A is answered in favour of the assessee and against the revenue. The other question as to whether it can be regarded as an equipment or appliance is answered in the negative.