Invoice value governs release of detained goods under GST, and authorities cannot enhance valuation beyond the invoice basis.

For release of detained goods under Section 129(1)(a) of the CGST Act, read with Section 20 of the IGST Act, the amount payable must be computed on the invoice and e-way bill value. The authorities cannot enhance valuation beyond the invoice value for that purpose. Applying that principle, the HC set aside the enhanced valuation order and required release of the goods on the invoice value basis, with the matter to proceed afresh accordingly.

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Issues: Whether goods detained under Section 129(1)(a) of the Central Goods and Services Tax Act, 2017 read with Section 20 of the Integrated Goods and Services Tax Act, 2017 could be released on the invoice value, and whether the authorities could enhance the valuation for computing the amount payable.

Analysis: The dispute centred on the proper basis for computation under Section 129(1)(a). The Court followed the existing view that the valuation for release of detained goods cannot be enhanced beyond the invoice value and that the statutory exercise under the provision must proceed on the basis of the invoice and e-way bill value.

Conclusion: The goods were required to be released on the value mentioned in the invoice, and the order enhancing the value was set aside.

Final Conclusion: The writ petition succeeded, and the impugned detention-related order was annulled with a direction to proceed afresh on the invoice valuation basis.

Ratio Decidendi: For purposes of Section 129(1)(a) of the Central Goods and Services Tax Act, 2017, the amount payable for release of detained goods must be determined on the invoice value and not on an enhanced valuation adopted by the authorities.

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