Modvat credit cannot be denied for procedural invoice defects when duty-paid receipt is otherwise established.

Modvat credit on furnace oil could not be denied merely because invoices lacked pre-authentication, were marked duplicate for transporter, or contained incomplete particulars, where duty-paid receipt was otherwise established. The inputs were supplied by a Central Government undertaking, the invoices indicated duty payment, the goods were delivered directly in tankers, and the supplier certified that duty had been paid. As the Revenue raised no doubt about the duty-paid character of the inputs and the defects were only procedural and outside the buyer's control, disallowance of credit was unjustified.

---

---

Issues: Whether Modvat credit on furnace oil could be denied on the basis of defects in the invoices, such as absence of pre-authentication, marking as duplicate for transporter, or incomplete particulars, when the goods were supplied by a Central Government undertaking and duty-paid nature was otherwise established.

Analysis: The inputs were supplied by Indian Oil Corporation, a Central Government undertaking, and the invoices indicated that duty had been paid. The invoices were consistent with the marketing method adopted by the supplier, and the goods were directly supplied in tankers. The supplier also confirmed by certificate that duty had been paid on the goods supplied. No doubt was raised by the Revenue about the duty-paid character of the inputs. The objections raised were only procedural in nature and were not matters within the buyer's control to ensure.

Conclusion: The defects in the invoices were not sufficient to deny Modvat credit, and the disallowance of credit was unjustified.

---