GST detention valuation must follow invoice value under section 129(1)(a), not an enhanced basis under section 129(1)(b).

In GST detention proceedings, the Court applied section 129(1)(a) of the CGST Act and held that release must be worked out on invoice value where that provision governs; the authorities were not justified in shifting to the alternative valuation basis under section 129(1)(b) read with section 20 of the IGST Act. Relying on earlier decisions, the Court found no reason to depart from that approach and directed fresh action in accordance with section 129(1)(a). The detention order was set aside.

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Issues: Whether the detained goods were liable to be released under section 129(1)(a) of the Central Goods and Services Tax Act, 2017, or whether the authorities could proceed under section 129(1)(b) of that Act read with section 20 of the Integrated Goods and Services Tax Act, 2017.

Analysis: The dispute centered on the correct statutory basis for release and computation in the detention proceedings. The Court accepted the petitioner's position that the goods were to be dealt with on the basis of the invoice value and that the authorities were not justified in adopting the alternative valuation basis under section 129(1)(b). Relying on the earlier decisions cited before it, the Court found no reason to take a different view.

Conclusion: The goods were held liable to be released under section 129(1)(a) of the Central Goods and Services Tax Act, 2017, and not under section 129(1)(b) of that Act.

Final Conclusion: The detention order was set aside and the authorities were directed to proceed afresh in accordance with section 129(1)(a) on the basis of invoice valuation.

Ratio Decidendi: In detention proceedings under the GST regime, valuation for release cannot be enhanced beyond the invoice basis where section 129(1)(a) applies.

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