Cenvat credit denial sustained where altered documents and fraudulent material failed to support the claimed service-tax input credit.

Cenvat credit was denied where the supporting service-tax documents were found unreliable and appeared altered to recast machinery-shifting charges as labour charges. The material relied upon did not establish genuine transmission of purchase orders to vendors and was treated as lacking evidentiary value, so the credit claim was rejected. The note also applies the principle that fraud vitiates proceedings and that a party seeking relief must approach the forum with clean hands; on that basis, relief based on fabricated or suppressed material was refused and the denial of credit was sustained.

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Issues: Whether the appellant was entitled to cenvat credit on the disputed service-tax paid inputs and whether the supporting documents produced to substantiate the claim could be relied upon.

Analysis: The disputed bills showed different handwriting and inserted descriptions suggesting that the documents had been altered to present machinery-shifting charges as labour charges. The purchase orders relied upon did not establish actual transmission to vendors and appeared to be test prints rather than original commercial documents. The evidence therefore did not inspire confidence, and the claim for credit was found to rest on material created to support inadmissible credit. Reliance was placed on the principle that a party approaching an adjudicatory forum must do so with clean hands and that fraud vitiates the proceedings.

Conclusion: The claim for cenvat credit was rejected, and the order denying the credit was upheld.

Final Conclusion: The appeal failed on merits because the supporting documents were disbelieved as fraudulent and the denial of cenvat credit was sustained.

Ratio Decidendi: Relief founded on altered or unreliable documents can be refused where the material shows fraud or suppression, since fraud vitiates the entitlement claimed and a litigant must approach the forum with clean hands.

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