Cenvat credit cannot be denied for delayed input service distributor registration when services were received and tax payment is verifiable.

Cenvat credit cannot be denied merely because input service distributor registration was obtained after the credit invoice when the services were actually received, tax had been paid, and the records allowed verification of the claim. The Tribunal treated the registration requirement as directory in this context, holding that prior ISD registration was a procedural condition and not a substantive bar to credit entitlement. On that basis, the denial of Cenvat credit was unsustainable and the assessee was entitled to relief.

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Issues: Whether Cenvat credit could be denied merely because the input service distributor registration was obtained after the credit invoice and the appellant's centralized registration was already in place.

Analysis: The appeal turned on whether non-registration as an input service distributor was a substantive bar to credit or only a procedural lapse. The Tribunal followed its earlier decision in the appellant's own case and the subsequent High Court decisions holding that, where services were received, tax had been paid, and records were available for verification, denial of Cenvat credit solely for want of prior ISD registration was not justified. The reasoning treated the registration requirement under the service tax registration rules and the Cenvat framework as directory in this context, and held that the irregularity was curable and did not extinguish the substantive credit entitlement.

Conclusion: The denial of Cenvat credit was unsustainable, and the issue was decided in favour of the assessee.

Final Conclusion: The impugned order was set aside and the appeal was allowed with consequential relief according to law.

Ratio Decidendi: Where the underlying services were received and tax was paid, Cenvat credit cannot be denied merely for procedural non-compliance with input service distributor registration requirements if the records support verification of the claim.

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