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Issues: Whether goods transported from one State to another could be detained under the CGST/SGST regime on allegations of misclassification and under-valuation, and whether such disputes were to be examined by the detaining authority or the assessing officer under the IGST regime.
Analysis: The movement of goods was inter-State, and the power invoked in the notice was traceable to the CGST/SGST framework, which was not the proper regime for such movement. The questions of classification and valuation required adjudication in assessment proceedings and not at the stage of detention by the detaining officer. Since the consignee was willing to accept the goods, continued detention was unwarranted. The notice was therefore to be treated as one under the IGST Act, and the assessing authorities were left free to proceed in accordance with law.
Conclusion: The detention was held unsustainable and the goods were ordered to be released on execution of a simple bond without sureties, in favour of the petitioner.
Final Conclusion: The writ petition succeeded, and the controversy was left to be addressed in the appropriate assessment proceedings under the inter-State tax regime.
Ratio Decidendi: Detention of inter-State goods cannot be sustained under the CGST/SGST machinery on disputes of classification or valuation, which must be decided in assessment proceedings by the competent assessing authority.