(1.) Heard both sides.
(2.) Appellant filled this appeal against the order passed by the Commissioner (Appeals) whereby the benefit of Modvat credit in respect of storage tanks was disallowed on the ground that storage tanks are merely used for the purpose of storage of gases manufactured by the appellant.
(3.) The appellants are engaged in the manufacture of various types of gases and they are availing the benefit of Modvat credit in respect of capital goods. The appellant availing the credit in respect of storage tanks as capital goods and the credit was denied.