Cenvat credit cannot be denied for invoice mismatches alone if actual receipt and use of inputs can be verified.

Cenvat credit should not be denied merely because invoice descriptions or quantities do not tally with account records if actual receipt and use of the inputs can be established by verifiable documents. Transport papers, weighment slips, production records and technical evidence may support receipt and consumption, and a mismatch alone is not decisive. Where the available record has not been properly examined, the correct course is fresh verification of actual receipt and utilisation before any final disallowance of credit.

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Issues: Whether Cenvat credit on inputs could be denied merely because the description and quantity in the invoices did not tally with the account records, without verifying actual receipt and utilization of the goods, and whether the matter required de novo verification.

Analysis: The input material was stated to have been received as alumina hydrate, and the dispute arose from the mismatch between the invoice description and the records showing calcined alumina. The record indicated that transport documents, weighment slips and other production records could establish receipt and use of the goods. A chartered engineer's report also indicated that hydrated alumina is used in the process of producing calcined alumina. Since such verifiable documents were not produced or were not properly examined by the adjudicating authority, the issue of actual receipt and consumption could not be finally resolved on the existing record.

Conclusion: The denial of Cenvat credit was not sustained on the existing verification and the matter was required to be sent back for de novo consideration.

Ratio Decidendi: Cenvat credit should not be denied solely on a mismatch in description or quantity if actual receipt and utilization of the inputs can be established by verifiable records; where such verification has not been properly undertaken, remand for fresh examination is warranted.

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