Invoice mismatch and e-way compliance breach sustained tax and penalty under the U.P. GST framework.

Orders imposing tax and penalty under the U.P. GST regime were sustained where the invoices did not match the verifying sheets with the mobile squad and the goods were transported in breach of Rule 138. The authorities treated the mismatch and non-compliance as fraudulent and levied tax and penalty under Section 129(3). In writ proceedings, no error in those factual findings was demonstrated, so the challenge to the penalty and the appellate rejection failed.

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Issues: Whether the orders imposing tax and penalty under Section 129(3) of the U.P. Goods and Services Tax Act, 2017, on the ground of invoice mismatch and violation of Rule 138 of the U.P. Goods and Services Tax Rules, 2017, were liable to be quashed.

Analysis: The impugned orders proceeded on the finding that the particulars in the invoices did not match the verifying sheets available with the mobile squad and that the petitioner had transported the goods in breach of Rule 138. The authorities below also recorded that the act was fraudulent and levied tax and penalty accordingly. No error in those findings was demonstrated in the writ proceedings.

Conclusion: The challenge to the penalty and the appellate rejection failed.

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