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{field 13} {field 14}

It is submitted that to implement the Energy Efficient Expansion of the Sugar Mill of the appellant that the appellant purchased the impugned structures to be installed for the fabrication of plant and machinery and thus, the structures purchased were not merely the staging structures, but was actually the sugar machinery, and thus, were falling under Chapter 84. The structure purchased being the capital goods that the appellant has rightly availed the Cenvat Credit. It is submitted that the adjudicating authorities below have overlooked that the impugned structures are the components/ spares/ accessories of the sugar machinery of the appellant.