E-way bill expiry during valid goods transit doesn't justify confiscation without proper inquiry into delay reasons

The Allahabad HC quashed confiscation proceedings against goods transported with expired E-way bills. The petitioner's goods transited from Uttar Pradesh to West Bengal with valid documents, but E-way bills expired on 12.3.2023 while goods were intercepted on 14.3.2023. No discrepancies were found in quality, quantity, or documentation. The petitioner claimed vehicle breakdown and driver illness caused the delay, but authorities failed to record findings regarding these submissions. The HC distinguished this case from precedent involving COVID-19 restrictions and remitted the matter back to the original authority for fresh consideration.

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Issues:
The issues involved in the judgment are the quashing of orders passed under UPGST Act 2017, release of seized goods, imposition of penalty, and the legality of transit of goods after expiry of E-way bills.

Quashing of Orders:
The petitioner filed a writ petition seeking to quash orders passed by Additional Commissioner and Assistant Commissioner under the UPGST Act 2017. The petitioner contended that the goods were detained due to expired E-way bills, despite no discrepancy in the goods. The authorities rejected the petitioner's explanation without justifiable grounds, leading to the quashing of the impugned orders.

Release of Seized Goods:
The petitioner, a registered company, faced detention of goods by respondent no.2 due to expired E-way bills during transit from Uttar Pradesh to West Bengal. The petitioner explained that delays were due to unforeseen circumstances like the driver falling ill and vehicle breakdown. Despite the lack of evidence discrediting the petitioner's claims, the authorities imposed penalties. The court ruled in favor of the petitioner, quashing the orders and directing the release of the detained goods.

Imposition of Penalty:
The respondent authorities proposed penalties under UPGST Act sections 129(1)(a) and 129(1)(b) for transiting goods with expired E-way bills. The petitioner's appeal against the penalty was rejected without proper consideration of the circumstances leading to the delay. The court found no justifiable grounds for rejecting the petitioner's claims and ruled that penalties were unjustified, leading to the quashing of the orders.

Transit of Goods After Expiry of E-way Bills:
The transit of goods from Uttar Pradesh to West Bengal was interrupted when the E-way bills expired before reaching the destination. The authorities detained the goods based on this expiration, alleging an intention to evade tax payment. The petitioner explained that delays were due to uncontrollable events, like the driver's illness and vehicle breakdown. Despite lack of evidence contradicting the petitioner's claims, penalties were imposed. The court found the authorities' actions unjustified, quashing the orders and remitting the matter for further consideration with evidence presentation and reasoned decision-making within specified timelines.

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