Cenvat credit denied for discrepant invoices and failure to show reasonable verification of input goods under Rule 9(3).

Cenvat credit was denied because the invoices and source documents did not match the goods actually supplied, showing inconsistent description, pricing and commodity details. On those facts, the assessee failed to prove that it had taken the reasonable steps required under Rule 9(3) of the Cenvat Credit Rules, 2004. The plea of lack of knowledge was insufficient against the concurrent factual findings that the inputs were non-duty-paid and that the assessee had no satisfactory explanation for not verifying their true nature. Authorities' reliance on cases involving bona fide receipt of duty-paid inputs was found inapplicable on the different factual matrix.

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Issues: Whether the assessee had taken reasonable steps within the meaning of Rule 9(3) of the Cenvat Credit Rules, 2004 so as to retain Cenvat credit on the inputs purchased, and whether any substantial question of law arose from the findings that the credit was availed on non-duty-paid goods supported by discrepant invoices and source documents.

Analysis: The materials on record showed that the description of goods in the invoices did not tally with the goods actually supplied and that the source documents indicated a different commodity from the one described to the assessee. The findings of fact recorded by the authorities below and affirmed by the Tribunal established inherent contradictions in price and description, and the assessee had no satisfactory explanation for not verifying the true nature of the inputs. The reliance placed on cases involving bona fide receipt of duty-paid inputs and absence of fraud was held inapplicable on the facts, since those decisions turned on different factual matrices. In the present case, the assessee's plea of lack of knowledge was insufficient to displace the concurrent factual findings.

Conclusion: The assessee failed to establish compliance with the requirement of reasonable steps, and the concurrent findings sustaining denial of Cenvat credit called for no interference.

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