Cenvat credit and invoice numbering: handwritten serial numbers are only a procedural defect when invoices are genuine and tax is paid.

Cenvat credit could not be denied merely because input service invoices bore handwritten serial numbers, as the rules required serial numbering but did not mandate pre-printed numbers. Where the invoices were genuine and the service tax had been paid by the service provider, the numbering defect was only a procedural irregularity and did not justify denial of credit. The Tribunal therefore held that credit remained admissible despite the invoice numbering defect.

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Issues: Whether Cenvat credit could be denied merely because the input service invoices bore handwritten serial numbers instead of pre-printed serial numbers.

Analysis: The dispute turned on the requirements governing invoices under the relevant credit and tax rules. The invoices were required to be serially numbered, but the rules did not insist that the serial number must be pre-printed. The record also showed that the service tax on the disputed invoices had been paid by the service provider, and there was no real dispute as to the genuineness of the invoices. In such circumstances, the defect in numbering or similar irregularities was only procedural and could not, by itself, justify denial of credit.

Conclusion: Cenvat credit could not be denied solely on the ground that the invoices contained handwritten serial numbers. The issue was decided in favour of the assessee.

Ratio Decidendi: Cenvat credit cannot be denied for a mere procedural irregularity in invoice numbering when the invoices are genuine and the tax payment by the service provider is not in dispute.

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