Cenvat credit cannot be denied for procedural invoice defects where payment of service tax remains the decisive issue.

Cenvat credit could not be denied solely because invoices carried handwritten serial numbers or because the service tax registration number was missing or overwritten. Rule 4A(1) of the Service Tax Rules, 1994 and Rule 11 of the Central Excise Rules, 2002 require invoices to be serially numbered and to contain prescribed particulars, but do not insist on pre-printed serial numbers. Those defects were treated as procedural, while the decisive issue remained whether service tax had actually been paid on the disputed invoices. As that factual aspect had not been conclusively examined, the matter was remanded for fresh adjudication.

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Issues: Whether Cenvat credit could be denied merely because the invoices bore handwritten serial numbers, and in some invoices the service tax registration number was missing or overwritten.

Analysis: The invoice requirements under Rule 4A(1) of the Service Tax Rules, 1994 and Rule 11 of the Central Excise Rules, 2002 require invoices to be serially numbered and to contain prescribed particulars, but do not mandate pre-printed serial numbers. The discrepancies regarding handwritten numbering and the absence or overwriting of the registration number were treated as procedural in nature. The decisive consideration was whether the underlying service tax had in fact been paid by the service provider against the disputed invoices. Since the record indicated that verification had been undertaken and that the factual aspect of payment of service tax had not been conclusively dealt with in the impugned order, the matter required reconsideration.

Conclusion: Cenvat credit could not be denied solely on the basis of the stated invoice discrepancies, and the matter was remanded for fresh adjudication on the question whether service tax had been paid on the disputed invoices.

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