CENVAT credit not denied for minor invoice defect where duty-paid inputs were received and used in manufacture.

CENVAT credit cannot be denied for a minor documentation defect where the inputs are shown to be duty paid, actually received, and used in manufacture. The fact that the bill of entry stood in the name of an entity whose dealer registration had been surrendered was treated as a procedural irregularity, not a substantive bar, because the credit documents were invoices issued by a registered dealer and the genuineness of the transaction was not in doubt. Credit was therefore rightly allowed, and the Revenue's challenge failed.

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Issues: Whether CENVAT credit could be denied merely because the bill of entry stood in the name of an entity whose dealer registration had been surrendered, when the inputs were received through invoices issued by a registered sister unit and the duty-paid nature, receipt and utilisation of the goods were not in dispute.

Analysis: The credit documents relied upon were invoices issued by a registered dealer, and the record showed no dispute regarding the duty-paid character of the goods or their receipt and use in the manufacture of the final product. The defect pointed out by Revenue was treated as a procedural irregularity, while the Commissioner (Appeals) had found that the prescribed document for credit under Rule 9(c) was the bill of entry and that substantive entitlement should not be defeated for a minor rectifiable lapse. In the absence of any doubt about the genuineness of the transaction or the utilisation of inputs, denial of credit was unwarranted.

Conclusion: CENVAT credit was rightly allowed and the Revenue's challenge failed.

Ratio Decidendi: A minor procedural defect in documentation does not justify denial of CENVAT credit where the duty-paid nature of the goods, their receipt, and their use in the final product are not disputed and the credit is supported by proper invoices from a registered dealer.

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