Cenvat credit cannot be denied for procedural lapse where input services were received, paid for, and used across registered centres.

Cenvat credit on input services used across multiple centres could not be denied merely because invoices were addressed to one office and no Input Service Distributor registration was taken. The services were received, paid for, and used in the assessee's taxable radio operations, so the invoice format and ISD omission were treated as procedural lapses. As the credit could have been regularised through distribution to other registered locations and the arrangement was revenue neutral, the substantive entitlement to credit prevailed over the technical deficiency. The denial of Cenvat credit was therefore held unsustainable.

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Issues: Whether Cenvat credit of service tax on input services received under common invoices, addressed to the Jaipur office but relating to other separately registered offices of the assessee, could be denied for want of Input Service Distributor registration and alleged procedural deficiency.

Analysis: The assessee was a single entity running taxable radio operations at multiple locations, and the input service invoices were not disputed. The services were admittedly received and paid for, and the credit related to services used across the assessee's centres. The absence of ISD registration and the fact that the invoices were raised in the name of the Jaipur office were treated as procedural in nature. The credit mechanism could have been regularised through ISD distribution, and the situation was found to be revenue neutral because the tax burden could have been availed at the other centres. In such circumstances, the substantive benefit of Cenvat credit was not to be denied merely on a technical lapse.

Conclusion: The denial of Cenvat credit was unsustainable, and the appeals were allowed in favour of the assessee.

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