CENVAT credit cannot be denied for a wrong unit address on invoices when records prove actual receipt and disclosure.

CENVAT credit was held admissible where invoices carried the address of a closed unit, because the services were in fact relatable to the operating unit and the records, including RG-1 and returns, supported availment at that location. The wrong address on some invoices was treated as a procedural lapse that did not defeat substantive credit. On limitation, regular return filing and disclosure of the credit negatived suppression or intent to evade tax, so the extended period could not be invoked. The demand was therefore time-barred and the assessee succeeded.

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Issues: Whether CENVAT credit could be denied merely because some invoices bore the address of the closed Yeshwanthpur unit instead of the Doddaballapur unit, and whether the demand was barred by limitation.

Analysis: The disputed invoices showed that the services were actually relatable to the Doddaballapur unit, which had commenced operations in 2008, while the Yeshwanthpur unit had stopped operations from January 2010. The material on record, including the RG-1 register and returns filed for the Doddaballapur unit, supported the claim that the credit was taken only at one location. The mention of the Yeshwanthpur address on some invoices was treated as a procedural lapse and not a substantive defect defeating credit. On limitation, regular filing of returns and disclosure of the credit negatived any allegation of suppression with intent to evade tax, so invocation of the extended period was unsustainable.

Conclusion: CENVAT credit was admissible and the demand was time-barred, so the appeal was allowed in favour of the assessee.

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