Cenvat Credit for Duty-Paid Inputs Survives Technical Invoice Defects When Receipt and Use in Manufacture Are Proven

Cenvat credit cannot be denied merely because invoices contain discrepancies, including use of duplicate or triplicate copies, when receipt of duty-paid inputs and their use in manufacture are established through bank records, gate registers and statutory documents. Minor defects in the dealer's invoices are treated as technical mistakes and do not defeat substantive entitlement where the duty-paid character of the inputs is not in dispute and the supplier's assessment is not being challenged at the recipient's end. On that basis, the assessee was entitled to credit and the Revenue's objection failed.

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Issues: Whether Cenvat credit could be denied on the ground of discrepancies in invoices and use of triplicate or duplicate copies, when receipt of duty-paid inputs and their use in manufacture stood established.

Analysis: The goods were found to have been received in the factory and used in manufacture, supported by bank records, gate registers and statutory documents. The defects in the invoices were treated as mistakes on the dealer's side and as technical discrepancies. The decision also proceeded on the basis that where payment of duty, receipt of inputs and their use are verifiable, credit cannot be denied merely because all particulars in the documents are not perfect. The authority relied on the settled position that the recipient cannot be denied credit when the duty-paid character of the inputs is not in dispute and the supplier's assessment is not being questioned at the recipient's end.

Conclusion: The assessee was entitled to Cenvat credit, and the Revenue's challenge failed.

Ratio Decidendi: Cenvat credit cannot be denied on mere technical defects in invoices where the duty-paid receipt and use of inputs in manufacture are established and the discrepancy does not affect the substantive entitlement.

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