Modvat credit remains available when duty-paid inputs and invoices are verifiable, even if the commercial invoice comes from an intermediary manufacturer.

Modvat credit could not be denied where duty-paid inputs were verifiable and the commercial invoice could be correlated with the duty-paid invoice issued by the job worker. The Tribunal treated the decisive factor as substantial compliance with the prescribed procedure: the goods were manufactured by the job worker, duty payment particulars tallied, and the documents matched on verification. It distinguished situations involving missing invoice copies or invoices issued by unrelated non-manufacturers. On those facts, credit was held admissible despite the commercial invoice being raised by an intermediary or principal manufacturer rather than the job worker.

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Issues: Whether Modvat credit could be denied merely because the goods were supplied under the manufacturer's job-worker invoices while the commercial invoice was raised by another related manufacturer, when the goods, duty payment particulars and invoice details were verifiable and matched.

Analysis: The relevant question was whether the documents taken together established receipt of duty-paid inputs and allowed correlation between the commercial invoice and the duty-paid invoice of the job worker. The Tribunal distinguished cases involving loss of invoice copies or invoices issued by unrelated non-manufacturers, and relied on prior decisions holding that where the goods and documents are verifiable and the transaction reflects substantial compliance with the prescribed procedure, Modvat credit cannot be denied. On the facts, the goods were manufactured by the job worker, duty had been paid, the particulars tallied, and the authorities had found the documents matching.

Conclusion: Modvat credit was admissible and could not be denied on the ground that the commercial invoice had been raised by the intermediary manufacturer. The denial of credit was set aside in favour of the assessee.

Ratio Decidendi: Where duty-paid inputs and the supporting documents are verifiable and mutually correlated, Modvat credit cannot be refused merely because the commercial invoice was issued by an intermediary or principal manufacturer instead of the job worker.

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