Composite invoice documents can validly support Modvat credit when they collectively satisfy prescribed notification requirements.

A composite document made up of a dealer's invoice and an endorsed manufacturer's invoice can support Modvat credit where the dealer is authorised to issue invoices and the document, read as a whole, contains the particulars required by Notification No. 15/94-C.E. (N.T.). The presence of duty details, invoice particulars and cross-reference to the manufacturer's invoice satisfied the prescribed requirements, and the joint defacement of both documents reinforced their treatment as one duty-paying document. On that basis, credit was held admissible and the denial of Modvat credit was set aside.

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Issues: Whether Modvat credit was admissible on the basis of a composite document consisting of a dealer's invoice together with an endorsed manufacturer's invoice, in the light of Notification No. 15/94-C.E. (N.T.) dated 30-3-1994.

Analysis: The document produced by the assessee was not to be viewed in isolation as either a mere endorsed manufacturer's invoice or a defective dealer's invoice. The dealer was authorised to issue invoices under the notification, and the composite document, read as a whole, contained the particulars required by the notification, namely the duty particulars, invoice details and cross-reference to the manufacturer's invoice. The fact that both documents were defaced together also supported the conclusion that the department treated them as part of the same duty-paying document.

Conclusion: The credit was admissible and the denial of Modvat credit was . The issue is decided in favour of the assessee.

Final Conclusion: The orders denying credit were set aside and the appeal succeeded with consequential relief according to law.

Ratio Decidendi: A composite invoice document issued by an authorised dealer is valid for Modvat credit if, when read as a whole, it satisfies the particulars prescribed by the governing notification.

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