Cenvat credit requires proven correlation between invoiced coils and received sheets; matter remanded for fresh adjudication.

Cenvat credit depended on establishing a proper correlation between the HR/CR coils described in the dealer's invoice and the HR/CR sheets actually received after cutting. The record showed that the appellant had not produced the specific linkage directed in the earlier remand, as the material submitted related only to sheets and the components made from them. Because that correlation remained unverified, the matter was remanded to the Original Adjudicating Authority for denovo adjudication, giving the appellant one further opportunity to establish the required nexus. Credit could be allowed only if the appellant proves the invoice-to-receipt correlation.

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Issues: Whether Cenvat credit could be allowed where the dealer's invoice described the goods as HR/CR coils but the appellant received HR/CR sheets, and whether the matter required remand for proper correlation of the materials.

Analysis: The dispute turned on whether the appellant had established a satisfactory correlation between the HR/CR coils shown in the dealer's invoice and the HR/CR sheets actually received after cutting of the coils. Earlier remand directions had required such correlation, but the record showed that the appellant had not produced the relevant correlation between the invoiced coils and the sheets received. The correlation submitted by the appellant related only to sheets and the components manufactured from them, which did not answer the specific direction issued earlier. In these circumstances, the matter warranted one further opportunity to establish the required linkage before the adjudicating authority.

Conclusion: The impugned order was set aside and the matter was remanded to the Original Adjudicating Authority for denovo adjudication. If the appellant establishes the required correlation, Cenvat credit may be allowed.

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