Modvat credit cannot be denied by reopening input valuation, and rubber-stamped invoice copy markings satisfy the formality.

For Modvat credit, the credit authority could not reopen the input supplier's assessable value to exclude packing and forwarding charges merely because they were shown separately in the invoice; that valuation question lay outside the scope of examining the buyer's credit entitlement, so the objection failed. An invoice was also treated as valid where the copies were marked "Original", "Duplicate" and "Triplicate" by rubber stamp rather than pre-printed, because the requirement was one of identification of copies, not printing format. The result was that both objections to Modvat credit were rejected and consequential relief followed.

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Issues: (i) Whether packing and forwarding charges, though shown separately in the invoice, could be excluded from the assessable value for the purpose of denying Modvat credit on duty paid thereon. (ii) Whether an invoice not pre-printed as "Original", "Duplicate" and "Triplicate" but rubber-stamped with those descriptions was valid for Modvat credit.

Issue (i): Whether packing and forwarding charges, though shown separately in the invoice, could be excluded from the assessable value for the purpose of denying Modvat credit on duty paid thereon.

Analysis: The question whether the input supplier had included the charges in the assessable value was held to be beyond the authority's scope when examining the buyer's entitlement to Modvat credit. The authority dealing with credit could not re-assess the goods for that purpose.

Conclusion: The exclusion of packing and forwarding charges from assessable value for denying Modvat credit was not justified, and the objection failed.

Issue (ii): Whether an invoice not pre-printed as "Original", "Duplicate" and "Triplicate" but rubber-stamped with those descriptions was valid for Modvat credit.

Analysis: The requirement was treated as one of marking the copies, not of printing those words on the invoice. Rubber stamping satisfied the legal requirement and met the prescribed formality.

Conclusion: The invoice was valid for Modvat credit.

Final Conclusion: The appeal succeeded on both surviving issues, and the appellants were granted consequential relief.

Ratio Decidendi: For Modvat credit, the credit authority cannot reopen assessable value of inputs for denying credit, and invoice-copy marking requirements are satisfied by a valid rubber stamp even without pre-printing.

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