Modvat credit cannot be denied for tariff-heading mismatch where inputs are identified and used in manufacture.

Modvat credit could not be denied merely because the Rule 57G declaration and the supplier's invoice referred to different tariff headings, where the inputs were otherwise identified and their use in manufacture was shown. The declaration described the material as a mineral-based special purpose oil used for slotting, and the process details and end-use were furnished. In the absence of proof that the goods received were different from the declared inputs or were not used in manufacture, a discrepancy in description or classification in the invoice did not by itself defeat credit. Credit was therefore admissible.

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Issues: Whether Modvat credit could be denied merely because the declaration under Rule 57G described the input under one tariff heading while the invoice showed a different heading, when the goods were otherwise identified and shown to be used in the manufacturing process.

Analysis: The declaration described the input as mineral based special purpose oil used for slotting, an essential part of manufacture, and the respondent had furnished the process details and end-use of the material. The difference between the heading mentioned in the declaration and the heading shown in the supplier's invoice was not shown by the Department to establish that the goods received were in fact a different product incapable of use in manufacture. In the absence of proof that the inputs were not the declared goods or were not used in the manufacture of the final products, a discrepancy in description or classification in the invoice could not by itself defeat credit.

Conclusion: Modvat credit was admissible and could not be denied solely on the basis of the mismatch in tariff description or heading.

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