Deemed credit for steel inputs fails when contemporaneous records describe the goods as plates, not sheets.

Deemed credit on steel inputs was denied where the goods were contemporaneously described in invoices, cash memos and RG 23A Part I records as plates of 5 mm thickness. The claim that the goods were actually sheets failed because there was no purchase order or other declaration showing that sheets had been ordered or received. In the absence of material establishing misdescription, the recorded description of plates prevailed, and the goods were treated as outside the deemed credit scheme. The demand was therefore sustained.

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Issues: Whether the appellants were entitled to deemed credit on steel goods described as plates, on the claim that the goods actually received were sheets and not plates.

Analysis: The claim that the inputs were sheets rested on the assertion of wrong description, but the record did not show any purchase order or declaration identifying the inputs as sheets. The contemporaneous documents, including the bills, cash memos and RG 23A Part I entries, described the goods as plates of 5 mm thickness. In the absence of material to establish that sheets had in fact been received, the finding that the goods were plates, and therefore outside the deemed credit entitlement, was sustained.

Conclusion: The appellants were not entitled to deemed credit and the demand was upheld.

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