Modvat credit cannot be denied for a procedural mismatch when inputs are received, used in manufacture, and properly declared.

Modvat credit could not be refused solely because the port of import shown in the certificate differed from the bill of entry, where the inputs were undisputedly received, used in manufacture, and covered by the required declaration. The mismatch was treated as a procedural irregularity, not a substantive breach of the scheme. On that basis, the departmental challenge failed and the credit allowed by the lower appellate authority was sustained.

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Issues: Whether Modvat credit could be denied merely because the certificate and duty-paying documents showed a mismatch in the port of import, when the inputs were otherwise used in manufacture and reflected in the declaration.

Analysis: The dispute concerned credit under the Modvat scheme. The mismatch between the Range Superintendent's certificate and the bill of entry was treated as a procedural discrepancy. The material consideration was that the department did not dispute receipt and use of the inputs in the manufacture of the final product, nor the filing of the requisite declaration covering the inputs and final product.

Conclusion: The procedural discrepancy did not justify denial of Modvat credit.

Final Conclusion: The departmental appeal failed and the credit allowed by the lower appellate authority was sustained.

Ratio Decidendi: Modvat credit cannot be denied on a mere procedural irregularity where the receipt and utilisation of inputs for manufacture are not in dispute and the substantive requirements of the scheme are otherwise satisfied.

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