Modvat credit admissibility upheld where prior declaration and later product declaration supported compliance for disputed inputs.

Modvat credit on the disputed input was admissible because the input had already been covered in the original declaration, and a later declaration for the final product was filed before the inputs were issued for use. The compliance sequence showed that the declaration requirements were substantially met, so there was no basis to disturb the order granting credit. The Revenue's challenge therefore failed, and the claim to credit was sustained.

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Issues: Whether Modvat credit on the disputed input was admissible despite the timing and form of the declaration covering the input and final product.

Analysis: The input had been included in the original declaration dated 24-3-1986. A further declaration covering the final product under Heading 84.21 was filed on 13-12-1991, and the disputed inputs were issued for utilisation after that declaration. In these circumstances, the prior declaration and subsequent compliance supported grant of credit, and no ground was made out to interfere with the order allowing the claim.

Conclusion: Modvat credit was admissible and the Revenue's challenge failed.

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