Cenvat credit cannot be denied for invoice vehicle-number discrepancies alone without evidence of non-receipt of inputs.

Cenvat credit cannot be denied merely because the vehicle numbers in invoices are incorrect if there is no corroborative evidence that the inputs were not received. The manufacturing and clearance of final products on payment of duty supported the inference that inputs were received and used, and the Revenue produced no material showing any alternative source of procurement or non-receipt from the registered dealers. On those facts, disallowance of credit, demand, and penalties were not sustainable, and the impugned order was set aside with consequential relief.

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Issues: Whether Cenvat credit could be denied solely on the basis of incorrect vehicle numbers shown in the invoices, in the absence of corroborative evidence that the inputs were not received.

Analysis: The denial of credit rested only on discrepancies in the vehicle numbers mentioned in the dealers' invoices. The final products were admittedly manufactured and cleared on payment of duty, which supported receipt and use of inputs. No corroborative material was produced to show that the goods were not received from the registered dealers or to identify any alternative source of procurement. The circumstances, including the absence of contrary evidence and the consistency of the manufacturing records, did not justify disallowance of credit.

Conclusion: Cenvat credit could not be denied on the sole ground of vehicle numbers in the invoices, and the demand and penalties were not sustainable.

Final Conclusion: The impugned order was set aside and all three appeals were allowed with consequential relief.

Ratio Decidendi: Cenvat credit cannot be denied merely on invoice discrepancies relating to vehicle numbers unless the Revenue adduces corroborative evidence showing non-receipt of inputs or an alternative source of procurement.

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