Detention of goods for missing online forms alone was unjustified when invoice and lorry receipt were available for verification.

Goods cannot be detained solely because online Form JJ and Form MM were not produced where the invoice and lorry receipt were available for verification. The High Court noted that the detention rested only on non-production of the computerized forms, while the accompanying transport and invoice documents were produced and could be checked by the authority. On that basis, the absence of the online forms by itself was held insufficient to justify continued detention, and release of the goods was warranted.

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Issues: Whether the goods could be detained solely on the ground that online Form JJ and Form MM were not produced, when the invoice and lorry receipt were available for verification.

Analysis: The detention was founded only on non-production of the computerized online forms. The invoice and lorry receipt had been produced, and those documents could be verified by the detaining authority. In the circumstances, the absence of the online forms by itself was not a sufficient basis to continue detention of the goods.

Conclusion: The detention was not justified on that sole ground, and the assessee was entitled to release of the goods.

Ratio Decidendi: Goods cannot be detained merely for non-production of online forms when the accompanying invoice and lorry receipt are available and capable of verification by the authority.

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