Mandatory printed invoice serial numbers govern Modvat credit; handwritten numbering does not satisfy the statutory condition.

Modvat credit depended on compliance with Rule 52A(6), which required each invoice to bear a printed serial number running for the whole financial year from 1 April. The requirement was treated as a mandatory revenue safeguard, not a mere procedural formality, because invoices were used as the basis for availing credit. A handwritten or rubber-stamped serial number did not satisfy that statutory condition. On that basis, Modvat credit was held inadmissible and the challenge to its denial failed.

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Issues: Whether Modvat credit could be denied where the invoice bore a handwritten serial number instead of a pre-printed serial number as required by Rule 52A(6) of the Central Excise Rules, 1944.

Analysis: Rule 52A(6), as substituted by Notification No. 4/94-C.E. (N.T.) dated 01.03.1994, required each invoice to bear a printed serial number running for the whole year beginning on 1 April. The requirement was treated as mandatory and was linked with the revenue safeguards introduced when invoices were made a basis for availing Modvat credit. The invoice requirement was distinguished from a mere procedural formality, and earlier Tribunal authority held that handwritten or rubber-stamped serial numbers did not satisfy the statutory mandate of a printed running serial number for the financial year.

Conclusion: The handwritten serial number did not meet the mandatory requirement, so Modvat credit was not admissible. The appeal failed.

Final Conclusion: The denial of Modvat credit was upheld and the challenge to the appellate order was rejected.

Ratio Decidendi: Where the statute requires a printed running serial number on the invoice as a mandatory safeguard for Modvat credit, compliance is substantive and handwritten substitution does not satisfy the condition.

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