Modvat credit requires strict documentary compliance; missing invoice particulars and unproven dealer registration render credit inadmissible.

Modvat credit was treated as available only on strict compliance with prescribed documentary and registration requirements. Credit could not be supported by the original invoice instead of the required duplicate copy, and invoices lacking essential particulars such as the manufacturer's details, invoice number and date, value, quantity, and duty particulars were held to be defective in substance. The defect was not cured by later supplementation, and dealer registration was regarded as a mandatory condition rather than a mere procedural formality. On that basis, the credit was denied and the denial was upheld.

---

---

Issues: Whether Modvat credit was admissible when taken on the basis of original invoices instead of the prescribed duplicate copy, when the invoices lacked essential particulars, and when the dealer's registration was not shown to have been obtained within the stipulated time.

Analysis: The prescribed scheme required credit to be supported by the proper document, namely the duplicate copy of the invoice, and credit could not be sustained on a different copy merely because another copy was allegedly available. Missing particulars such as the manufacturer's name and address, invoice number and date, value, quantity, and duty details affected the authenticity of the document and could not be cured by later communications. The requirement that a dealer issuing invoices be registered was treated as mandatory, not merely procedural, and the relaxed treatment under the departmental instruction did not dilute the underlying statutory obligation. The defect was therefore substantive and not a curable technical lapse.

Conclusion: Modvat credit was not admissible and the denial of credit was upheld.

Ratio Decidendi: Credit under the Modvat scheme can be claimed only on strict compliance with the prescribed documentary and registration requirements, and defects going to the mandatory conditions are not cured by subsequent supplementation or by possession of other invoice copies.

---