CENVAT credit cannot be denied for technical invoice defects or lack of separate premises registration under centralised billing.

CENVAT credit should not be denied on a purely technical defect where debit notes and annexures, read together, contain the required particulars and the receipt and use of the input service are otherwise established. The document requirements under the Service Tax and CENVAT rules are meant to verify tax payment and service receipt, not to impose a rigid single-page format. Centralised registration of the office handling billing and accounting is sufficient where the service tax rules permit it, and individual premises used to render services do not need separate registration. On that basis, the credit objection and related demand and penalty were unsustainable.

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Issues: (i) Whether CENVAT credit could be denied merely because the debit notes and annexures did not place all required particulars on a single page. (ii) Whether credit could be denied on the ground that the individual premises from which services were rendered were not separately registered when the registered office had centralised billing and accounting.

Issue (i): Whether CENVAT credit could be denied merely because the debit notes and annexures did not place all required particulars on a single page.

Analysis: The document requirement under the Service Tax Rules and the CENVAT Credit Rules is intended to verify payment of tax and receipt of the input service. The relevant rules require specified particulars, but do not prescribe a rigid format or require that all particulars must appear on one page. Where the document, read with its annexure, contains the necessary particulars and the receipt and use of the input service are not in dispute, the credit cannot be denied on a purely formal objection.

Conclusion: The objection based on the debit notes and annexures was untenable and denial of credit on this ground was not justified.

Issue (ii): Whether credit could be denied on the ground that the individual premises from which services were rendered were not separately registered when the registered office had centralised billing and accounting.

Analysis: Rule 4(2) of the Service Tax Rules, 1994 recognised registration of the office from where centralised billing or centralised accounting was carried on. Once the appellant had obtained such centralised registration, there was no requirement to separately register each premises from which services were rendered. A contrary view would defeat the express scheme of the rule.

Conclusion: The objection based on non-registration of individual premises was unsustainable and could not defeat the credit.

Final Conclusion: The demand and penalty were unsustainable in law, and the appeal succeeded with consequential relief.

Ratio Decidendi: Credit cannot be denied on technical form alone if the document, taken as a whole, contains the required particulars and the input service is otherwise established, and centralised registration of the office is sufficient where the rules permit it.

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