Input duty credit cannot be denied for a mere certificate defect when records verify duty-paid inputs and correlation.

Credit on inputs could not be denied merely because the certificate accompanying differential duty payment was not in the precise form preferred by the department, where the certificate was in the prescribed proforma, countersigned by the jurisdictional Superintendent, and the excise records were sufficient to correlate the goods despatched, lifted from the stockyard, and received by the downstream manufacturer. Rejection based only on the departmental objection to form was unwarranted. The disallowance of credit was set aside, and the matter was remanded for verification of the correctness of the inputs and supporting documents.

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Issues: Whether credit of duty on inputs could be denied on the ground that the certificate accompanying differential duty payment was not in the precise form accepted by the department and whether the matter required fresh verification of the supporting records.

Analysis: The certificate issued in relation to the differential duty was in the prescribed proforma and was countersigned by the jurisdictional Superintendent. The relevant excise documents were sufficient to establish correlation between the goods despatched, lifted from the stockyard, and received by the downstream manufacturer. Denial of credit without verifying the available documents was unwarranted, and the objection raised to the departmental proforma itself could not sustain the rejection.

Conclusion: The disallowance of credit was set aside and the matter was remanded to the Assistant Commissioner for verification of the correctness of the inputs and related documents. The assessee obtained a partial relief.

Ratio Decidendi: Credit on inputs cannot be denied merely for a formal defect in the supporting certificate where the relevant excise records can verify the duty-paid nature and identity of the inputs.

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