Modvat credit requires factual comparison of inputs before denial where product descriptions differ.

Modvat credit could not be denied merely because the declared input, "Steel Round 'F'," differed in description from the received input, "Steel Step Forging 'F'," where both were said to be forged products used for making concest rolls. The lower authorities had not examined the factual plea that the two items were essentially similar, and that comparison was central to credit entitlement. The matter was therefore remanded for de novo determination of whether the two inputs were essentially the same product; if they were, Modvat credit was to be allowed, and if not, the credit claim would fail.

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Issues: Whether Modvat credit could be denied solely because the input declared as "Steel Round 'F'" differed in description from the input actually received as "Steel Step Forging 'F'", and whether the matter required fresh examination on the question whether both products were essentially similar.

Analysis: The declared and received inputs were both asserted to be forged products used for making concest rolls, with the alleged difference lying mainly in shape and description. The lower authorities had not examined this factual plea. Since the availability of Modvat credit depended on whether the two items were essentially the same product, the issue went to the root of the dispute and required factual determination before credit could be refused.

Conclusion: The matter was remanded to the original authority for de novo determination of whether "Steel Round 'F'" and "Steel Step Forging 'F'" were essentially similar products. If they were, Modvat credit was to be allowed; if not, the appellants would not be entitled to the credit.

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