Cenvat credit computation requires clear invoice-wise records before denial can be sustained; matter remanded for fresh adjudication.

Denial of Cenvat credit could not be sustained where the record did not clearly establish invoice-wise duty paid, credit taken, and admissible credit calculations under Rule 3(7)(a). The show cause notice and impugned orders failed to explain how the admissible credit had been computed, and the annexure figures did not consistently match. Because the factual foundation for testing credit eligibility was incomplete, the Tribunal held that the calculations required fresh examination. The matter was remanded to the lower authority for a fresh order with clear invoice-wise computation of duty paid, credit taken, and admissible credit.

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Issues: Whether the denial of Cenvat credit could be sustained when the record did not clearly show the invoice-wise duty paid, credit taken, and admissible credit calculations, and whether the matter required remand for fresh adjudication.

Analysis: The impugned orders and the show cause notice did not clearly set out the manner in which admissible credit had been computed. The figures in the annexure did not consistently match, and the lower authorities had not examined the break-up of duty paid on each invoice or the basis on which the credit available was worked out. In these circumstances, the Tribunal found that the factual foundation necessary to decide admissibility of credit under Rule 3(7)(a) was incomplete and the calculations required fresh examination.

Conclusion: The denial of credit could not be finally affirmed on the existing record, and the matter was remanded to the lower authority for fresh orders with clear invoice-wise computation of duty paid, credit taken, and admissible credit.

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