Cenvat credit cannot be denied on a mere defect in dealer particulars when receipt, consumption, and duty-paid documents are established.

Cenvat credit on inputs cannot be denied merely because the registered dealer's premises or particulars are found to be non-existent, shifted, or otherwise defective, where receipt and consumption of the goods in the factory are not disputed and the duty-paid character of the inputs is verifiable from invoices and related documents. The applicable rules require reasonable steps and supporting duty-payment documentation, but absence of a finding that the goods were not received or that duty was unpaid defeats a purely technical objection. On that footing, the assessee was entitled to the credit.

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Issues: Whether Cenvat credit could be denied merely because the registered dealer's premises were found to be non-existent or shifted, when the inputs were received, consumed, and supported by invoices; and whether the assessee had failed to take reasonable steps under the applicable Cenvat credit rules.

Analysis: The only substantive dispute was the entitlement to Cenvat credit on inputs procured from registered dealers whose address was alleged to be fictitious. The material finding was that the orders below did not dispute receipt and consumption of the inputs in the factory, nor did they negate the duty-paid character of the goods or the correctness of the invoice particulars as to procurement and duty-paying documents. The applicable rules required the recipient to take reasonable steps and to maintain verifiable duty-paid documentation, but the record showed no finding that the goods were not received or that the duty reflected in the first-stage dealer's documents was not paid. In such circumstances, the cited High Court decisions supported the view that credit cannot be refused on a mere technical objection relating to the dealer's address or registration status when the substantive requirements are otherwise satisfied.

Conclusion: Cenvat credit could not be denied on the ground urged by the Revenue, and the assessee was entitled to the credit.

Ratio Decidendi: Where receipt and consumption of duty-paid inputs are not disputed and the relevant duty payment is verifiable from the documents, Cenvat credit cannot be denied merely because the registered dealer's premises or particulars are found defective or doubtful.

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