Expired e-way bill detention upheld where no timely extension was sought and the vehicle breakdown explanation was rejected.

An expired e-way bill that was not extended within the time permitted under Rule 138(10) of the RGST/CGST Rules, 2017 supported detention of the vehicle and related orders. The court found that the e-way bills had remained valid only until 31.12.2022, the vehicle was seized after expiry, and no timely extension was sought within the prescribed eight-hour window. The explanation of vehicle breakdown was rejected because the stated location and travel claim were inconsistent with the asserted ability to reach Noida within the validity period. The challenge to the detention and consequential relief failed, and no refund was warranted.

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Issues: Whether the petitioner was entitled to quashing of the detention and consequential orders and refund of the amount despite the e-way bill having expired and not having been extended within the prescribed time.

Analysis: The e-way bills were valid up to 31.12.2022 and were not extended. The vehicle was seized on 01.01.2023 after expiry of the e-way bill period. Under Rule 138(10) of the RGST/CGST Rules, 2017, extension was permissible within eight hours from expiry. The defence of vehicle breakdown was not accepted, since the asserted location of the vehicle on 31.12.2022 was inconsistent with the claimed ability to reach Noida within the validity period, and no timely extension was sought.

Conclusion: The challenge to the impugned orders failed and no refund or other relief was warranted.

Ratio Decidendi: Where an e-way bill expires without extension as permitted by the governing rules, detention based on carriage after expiry cannot be interfered with on an unconvincing explanation of vehicle breakdown.

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