Modvat credit cannot be denied for a mere description mismatch where the declared and supplied inputs are classifiable alike.

Modvat credit on cast iron inserts was examined where the declaration referred to MCI inserts but the goods supplied were SGCI inserts. The note states that both items were used in sleeper manufacture, were treated as classifiable under the same heading, and that the description mismatch alone did not justify denial of credit when the underlying input had been duly declared and the issue was already covered by earlier Tribunal authority. On that basis, the denial of Modvat credit was considered unsustainable.

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Issues: Whether Modvat credit on SGCI inserts could be denied merely because the declaration mentioned MCI inserts.

Analysis: The declared and supplied inserts were both cast iron inserts used in the manufacture of sleepers and were treated as classifiable under the same heading. The mismatch in description between MCI inserts and SGCI inserts did not justify denial of credit when the underlying input had been duly declared and the issue stood covered by earlier Tribunal authority.

Conclusion: The denial of Modvat credit was unsustainable and the appeal was allowed.

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