Modvat credit cannot be denied for omission of PLA entry in invoices when the governing notification does not require it.

Modvat credit could not be denied merely because invoices did not mention the PLA debit entry where the invoices otherwise contained the relevant particulars, including the rate and amount of duty. Notification No. 33/94-C.E. (N.T.) did not require any reference to PLA entry as a condition for credit, so insisting on that detail imposed an extraneous requirement not found in the notification. The operative principle is that credit cannot be refused for omission of a non-mandatory invoice entry when the governing provision does not prescribe it.

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Issues: Whether Modvat credit could be denied solely because the invoices did not show the PLA debit entry.

Analysis: The invoices were found to contain the relevant particulars, including the rate and amount of duty. Notification No. 33/94-C.E. (N.T.) did not require any mention of PLA entry in the invoice. The denial of credit was therefore based on an extraneous requirement not found in the notification.

Conclusion: The requirement of mentioning PLA entry in the invoices was not mandatory, and Modvat credit could not be denied on that ground.

Ratio Decidendi: Where the governing notification does not prescribe mention of PLA entry as a condition for credit, Modvat credit cannot be refused merely for omission of that entry in the invoice.

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