Input tax credit requires proof of registered dealer status, but goods vehicles used in taxable business qualify as capital goods.

Input tax credit must be affirmatively substantiated by the dealer claiming it, and where the selling dealer's registered status or valid TIN is not established, the credit is not admissible. On the purchases from M/s. Healthy Life Agro Foods, the assessee failed to discharge that burden, so credit was denied. Goods vehicles used in the course of taxable business qualify as capital goods under the statutory scheme, so credit on the canter fitted with tanker was admissible. Where other capital goods were unsupported by the prescribed return and records, the claim was not proved, and credit on those items was denied.

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Issues: (i) Whether input tax credit could be denied on purchases made from M/s. Healthy Life Agro Foods on the ground that the dealer was not shown to be a registered dealer with a valid TIN. (ii) Whether input tax credit was admissible on the goods vehicle purchased and used in the business. (iii) Whether input tax credit could be denied on other capital goods for want of supporting returns and evidence.

Issue (i): Whether input tax credit could be denied on purchases made from M/s. Healthy Life Agro Foods on the ground that the dealer was not shown to be a registered dealer with a valid TIN.

Analysis: The claim for input tax credit depended on proof that the selling dealer was a registered dealer and that the transaction satisfied the statutory requirements. The records showed that the TIN mentioned in the invoice was invalid, that no dealer was registered under that number, and that the assessee did not establish that the seller was a bona fide registered dealer. The statutory burden to substantiate entitlement to input tax credit lay on the dealer claiming it. On the material on record, that burden was not discharged.

Conclusion: The issue was decided against the assessee; input tax credit on purchases from M/s. Healthy Life Agro Foods was not admissible.

Issue (ii): Whether input tax credit was admissible on the goods vehicle purchased and used in the business.

Analysis: The definition of capital goods included goods vehicles used in the course of business other than for sale, and the provision governing input tax on capital goods permitted deduction where such goods were used in business for taxable activities. The canter fitted with tanker was purchased for transportation of taxable goods in the course of business, and the statutory scheme supported allowance of input tax credit on such capital goods.

Conclusion: The issue was decided in favour of the assessee; input tax credit on the goods vehicle was admissible.

Issue (iii): Whether input tax credit could be denied on other capital goods for want of supporting returns and evidence.

Analysis: The claim for those capital goods was not supported by the required return and relevant records. The statutory requirement was that the claim be made with the necessary documents and in the prescribed return process. In the absence of such supporting material, the entitlement to input tax credit on those items was not established.

Conclusion: The issue was decided against the assessee; input tax credit on the other capital goods was not admissible.

Final Conclusion: The appeal succeeded only to the limited extent of the goods vehicle, while the denial of input tax credit on the disputed purchases and the remaining capital goods was sustained.

Ratio Decidendi: Entitlement to input tax credit must be affirmatively proved by the dealer, and while goods vehicles used as capital goods in taxable business qualify for deduction, credit can be denied where the selling dealer's registered status is not established or the claim is unsupported by the prescribed records.

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