Mandatory printed invoice serial numbers under Modvat rules; rubber-stamped numbers were insufficient and credit denial stood.

Modvat credit could be denied where invoices did not bear the mandatory printed serial numbers required to run through the full financial year. The rule distinguished between mere marking and the specific statutory requirement of printing, and rubber-stamped serial numbers were held not to satisfy that condition. The requirement was treated as mandatory, so the invoices failed to comply with Rule 57GG(5) and the denial of Modvat credit was upheld against the assessee.

---

---

Issues: Whether Modvat credit could be denied where the invoices were not pre-authenticated and did not bear printed serial numbers, but carried rubber-stamped serial numbers instead.

Analysis: Rule 57GG(5) required each invoice to bear a printed serial number running for the whole financial year, and the requirement was couched in mandatory terms. Printing denotes a different process from rubber stamping, and rubber-stamped numbers could not satisfy the statutory condition of a running printed serial number for the full financial year. The distinction between mere marking under Rule 57GG(4) and the specific requirement of printed serial numbers under Rule 57GG(5) was material, and the latter could not be diluted by analogy with cases involving rubber stamping for other endorsements.

Conclusion: The requirement of printed serial numbers was mandatory, rubber stamping did not meet the statutory mandate, and the denial of Modvat credit was upheld against the assessee.

---