Transit document compliance under VAT law: valid invoice and transport records were sufficient to defeat detention of goods.

Detention of goods in transit under the Tamil Nadu VAT regime was found unjustified where the carrier produced the invoice, LR copy and other accompanying transport documents, and the invoices showed the consignee's TIN number. Section 67(5) and Rule 15(3) were read to require prescribed transit documents, but the Court treated valid invoices and supporting transport records as sufficient compliance on these facts. The circular relied upon further clarified that movement of goods with a valid invoice does not, by itself, constitute an offence relating to movement of goods. The goods and vehicle were therefore released.

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Issues: Whether the detention of goods in transit under the Tamil Nadu Value Added Tax Act was justified when the invoice and accompanying transport documents were produced and the consignee's TIN number was mentioned in the invoices.

Analysis: Section 67(5) of the Tamil Nadu Value Added Tax Act, 2006 requires the carrier to possess the prescribed transit documents, and Rule 15(3) requires a bill of sale or delivery note with the goods vehicle record or similar transport record. The goods vehicle was found carrying invoices and the LR copy, and the invoices reflected the consignee's TIN number. On those facts, the ground that the vehicle lacked requisite documents could not be sustained. The circular relied upon by the Court also clarified that movement of goods accompanied by a valid invoice satisfies the statutory requirement and does not by itself justify action as an offence relating to movement of goods.

Conclusion: The detention was unlawful and the goods and vehicle were ordered to be released.

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