Provisional release of detained goods allowed where e-way bill, tax invoice, and prior deposits sufficiently secured revenue interest.

Intercepted goods accompanied by an e-way bill and tax invoice were directed to be released when the revenue interest was already substantially secured by the penalty deposit and part-payment of tax. The HC treated the remaining tax demand as a further condition for provisional release and permitted the petitioner to deposit the balance 70% in cash before release of the detained goods and vehicle. The operative principle is that, where compliance documents are produced and the revenue is adequately protected by prior deposits, provisional release may be ordered on payment of the remaining demand.

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Issues: Whether the petitioner was entitled to release of the detained goods and vehicle on compliance with further tax deposit conditions.

Analysis: The goods were intercepted in transit with the e-way bill and tax invoice already produced. The petitioner had deposited the penalty amount and a part of the tax demand, and the Court found that the revenue interest was sufficiently secured. In these circumstances, the petitioner was permitted to deposit the remaining 70% of the tax demand in cash as an additional condition for release.

Conclusion: The petitioner was held entitled to release of the goods and vehicle upon depositing the remaining 70% of the tax demand.

Final Conclusion: Relief was granted for release of the detained goods and vehicle, subject to compliance with the further deposit condition.

Ratio Decidendi: Where intercepted goods are accompanied by the e-way bill and tax invoice and the revenue stands substantially secured by deposits already made, provisional release may be ordered on payment of the balance tax demanded.

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