Modvat credit cannot be denied for minor invoice defects or a later registration condition applied to earlier transactions

Modvat credit cannot be denied for minor procedural defects where the invoice showed the head office address but was issued from the registered godown, and the discrepancy did not affect substantive entitlement. The invoice also contained the manufacturers' particulars, so the disclosure requirement was satisfied. A dealer or agent registration condition introduced by later notification could not be applied to invoices issued before it came into force. Credit was therefore admissible.

---

---

Issues: Whether Modvat credit could be denied on the grounds that the invoice showed a different address from the registration certificate, that the manufacturers' particulars were not stated as required, and that the dealer or agent was not registered when the invoice was issued.

Analysis: The discrepancy in the address was explained as the invoice bearing the head office address while being issued from the registered godown, and this was treated as a minor lapse not affecting the substantive entitlement to credit. The invoice also contained the manufacturers' particulars, so the requirement of disclosure was satisfied. As regards registration of dealers or agents, the relevant requirement arose only with Notification No. 32/94 dated 4-7-1994, whereas the invoice in question was dated earlier; the later condition could not be applied to deny credit for an earlier transaction.

Conclusion: Denial of Modvat credit was unjustified and the credit was admissible to the appellants.

Ratio Decidendi: Substantive Modvat credit cannot be denied for minor procedural defects, and a subsequent registration requirement cannot be used to disallow credit for invoices issued before that requirement came into force.

---