Cenvat credit declaration and invoice correlation must be read as a whole; mismatched quantities alone do not prove different goods.

A declaration under Rule 57G was construed as a whole: the broad description of inputs as MS Plates and GP Sheets was held to cover the goods actually received, and the stated tariff heading was treated as only a general qualifier, making the difference in tariff classification immaterial. Invoice correlation also could not be rejected merely because the manufacturer's invoice and the registered dealer's invoice showed different quantities or duty amounts, where the invoices otherwise reflected the onward sale chain and no independent evidence proved that the goods were different. Credit disallowance was therefore set aside and consequential relief followed.

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Issues: (i) Whether the declaration under Rule 57G, describing the inputs as MS Plates and GP Sheets with Tariff Heading 7909, covered the actual inputs received under Tariff Headings 7208.11 and 7210.19. (ii) Whether the goods covered by the invoices issued by the registered dealer were correctly held to be uncorrelated with the goods originally purchased from the manufacturer.

Issue (i): Whether the declaration under Rule 57G, describing the inputs as MS Plates and GP Sheets with Tariff Heading 7909, covered the actual inputs received under Tariff Headings 7208.11 and 7210.19.

Analysis: The declaration had to be read as a whole. The description of the inputs as MS Plates and GP Sheets was broad enough to cover the goods received, and the tariff heading and sub-heading were only broadly qualifying the description. Since the declaration did not specify a particular size or narrow class of goods, the difference in tariff heading and sub-heading was held to be immaterial.

Conclusion: This issue was decided in favour of the appellant.

Issue (ii): Whether the goods covered by the invoices issued by the registered dealer were correctly held to be uncorrelated with the goods originally purchased from the manufacturer.

Analysis: The lower authorities were found to have misread the invoices. The manufacturer's invoice reflected the sale to the registered dealer, while the dealer's invoice reflected the quantity sold onward to the appellant. Non-correlation could not be inferred merely from the difference in quantities or duty amounts shown in the two sets of invoices, and no other evidence such as marking was produced to establish non-correlation.

Conclusion: This issue was decided in favour of the appellant.

Final Conclusion: The disallowance of the credit was set aside and the appeal was allowed with consequential relief.

Ratio Decidendi: A declaration for excisable inputs must be construed as a whole, and invoice correlation cannot be rejected merely because the manufacturer's invoice and the dealer's invoice show different quantities or duty amounts unless independent evidence establishes that the goods are not the same.

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