Cenvat credit on documentary proof cannot be denied unless Revenue disproves genuine receipt and invoices as paper transactions.

Denial of Cenvat credit for alleged non-receipt of goods was found unsustainable where the assessee produced invoices, RG-23 entries and weightment slips supporting receipt and credit availed on documentary record. Rule 9(3) of the Cenvat Credit Rules, 2002 requires reasonable verification of supplier identity and document genuineness, but once such records are furnished the burden shifts to the Revenue to prove that the invoices reflected only paper transactions. As no inquiry was made at the supplier or transporter level, and cancellation or non-existence of the dealer's registration was not established, the allegation of non-receipt was not proved.

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Issues: Whether the denial of Cenvat credit on the allegation that the goods were not physically received and the invoices represented only paper transactions was sustainable.

Analysis: The appellant produced invoices and corresponding RG-23 entries, along with supporting weightment slips, showing availing of credit on the strength of documentary record. Rule 9(3) of the Cenvat Credit Rules, 2002 requires the recipient to take reasonable steps regarding the identity and address of the supplier and the genuineness of the documents, but once invoices and related records are produced, the burden shifts to the Revenue to establish that the transaction was only on paper. The investigation was not carried out at the end of the manufacturer-supplier or the transporter, and the existence or cancellation of the dealer's registration was not established to displace the documentary evidence.

Conclusion: The allegation of non-receipt of goods was not proved, and denial of Cenvat credit was unsustainable in favour of the assessee.

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