Interception-stage detention requires more than suspicion when transport documents disclose sprinkler-system goods and no intent to evade tax appears.

Goods accompanied by the delivery memo and transfer invoice could not be detained merely because physical verification raised a discrepancy. The documents had to be read together, and the description disclosed the goods as a complete sprinkler system or its parts. The use of the expression "complete set" did not by itself show an intention to evade tax. The apparent mismatch gave rise only to suspicion; whether the goods were ordinary pipes or sprinkler-system components was a matter for assessment, not interception-stage detention. The power of seizure and detention was treated as a cautious measure to prevent evasion, not to harass a bona fide registered dealer, so detention was not justified.

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Issues: Whether the seizure and detention of the goods transported by the registered dealer was justified on the ground of discrepancy between the delivery memo and the physical verification, and whether the authorities could treat the goods as liable to detention at the interception stage.

Analysis: The goods were accompanied by the relevant documents, and the delivery memo and the transfer invoice were to be read together. The description in the documents showed disclosure of the goods as a complete sprinkler system or its parts, and the mere use of the expression "complete set" did not, by itself, establish an intention to evade tax. The Court held that the apparent mismatch created at most a suspicion, while the question whether the goods were ordinary pipes or sprinkler-system components was a matter for assessment and could not justify detention on presumption and assumption. The power of seizure and detention was held to be a cautious power meant to prevent evasion and not to harass a bona fide registered dealer.

Conclusion: The seizure and detention were not justified, and the revision succeeded in favour of the assessee.

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