Prescribed documentary proof governs excise credit, while deemed duty-paid stock may still qualify under the proviso.

Rule 56A required the prescribed documents to prove excise-duty payment on steel sheets and plates, and invoices alone were not accepted as a substitute. The plea of substantial compliance was rejected because the rule did not leave discretion to accept other evidence in place of the specified proof. The proviso to Rule 56A(3), however, allowed the Central Government to treat specified stocks as duty-paid and permit credit on conditions it prescribed, so claims for stocks lying with the petitioners after the relevant date were to be examined under that proviso in accordance with government directions.

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Issues: Whether the petitioners were entitled to credit of excise duty on steel sheets and plates without producing the documents specifically prescribed by Rule 56A, and whether they could nevertheless claim benefit under the proviso to Rule 56A(3) for stocks treated as duty-paid.

Analysis: The Rule required production of particular documents and did not confer discretion to accept other evidence as a substitute for the prescribed proof. The petitioners' invoices did not amount to compliance with the documentary requirements of the Rule, and the plea of substantial compliance was rejected. At the same time, the proviso to Rule 56A(3) permitted the Central Government to direct that specified stocks may be deemed duty-paid and that credit may be allowed at such rate and subject to such conditions as it may prescribe. The petitioners were therefore entitled to have their claim examined under that proviso for stocks lying with them after the relevant date, in accordance with the Government's directions.

Conclusion: The insistence on the prescribed documents was upheld, but the petitioners were held entitled to credit under the proviso to Rule 56A(3) to the extent permitted by the Central Government's directions.

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