Detention for missing online Form JJ was unsustainable where invoice and lorry receipt were produced and Rule 15 allowed other records.

Goods could not be detained solely for non-production of online Form JJ when the invoice and lorry receipt were produced and the amended Rule 15 permitted consideration of accompanying transport records. The court noted that the departmental circular also allowed officers to examine other available documents before deciding on detention. As the detention rested only on absence of the computer-generated form despite relevant supporting records being available, it was held unsustainable and the goods and vehicle were ordered to be released.

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Issues: Whether goods could be detained solely because the online Form JJ was not produced, notwithstanding the production of the invoice and lorry receipt and the amended Rule 15 governing the accompanying documents.

Analysis: The amended Rule 15 required production of specified transport documents, but the record also showed that the department's circular permitted officers to examine other available documents and earlier movement of similar goods before taking a decision. The detention was based only on non-production of the computer-generated Form JJ. The invoice and lorry receipt produced by the petitioner were relevant materials that could be considered under the amended rule, and the detention could not rest on a single missing form when other accompanying records were available.

Conclusion: The detention on the sole ground of non-production of online Form JJ was unsustainable, and the writ petition succeeded in favour of the assessee.

Final Conclusion: The impugned detention was quashed and the goods and vehicle were directed to be released forthwith.

Ratio Decidendi: Where the governing transport rule permits consideration of accompanying records, goods cannot be detained merely for absence of one online form if other relevant documents are produced.

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