GST detention for missing delivery address in registration cannot survive once the place is later regularised.

Detention and penalty under GST were not sustained where the consignee's delivery address was added as an additional place of business after interception but before the impugned order, and the registration amendment had already been approved. The HC treated the matter as covered by earlier precedent holding that the absence of prior inclusion of the delivery address in the GST registration is not, by itself, a valid basis to continue detention once the registration has been regularised. Relief was granted, the writ petition was allowed, and the penalty amount was directed to be credited back to the petitioner's Electronic Cash Register.

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Issues: Whether detention and penalty under the GST law were sustainable when the consignee's place of business was added as an additional place of business after the consignment was intercepted.

Analysis: The consignment was intercepted because the Thoothukudi address was not reflected as an additional place of business at the time of transport, but the registration was amended shortly thereafter and approved before the impugned order. The issue was treated as covered by earlier decisions granting relief in similar circumstances, where the absence of prior inclusion of the delivery address in the GST registration was not treated as a valid basis to sustain detention once the registration stood amended.

Conclusion: The detention and consequential penalty were not sustained, and relief was granted in favour of the petitioner.

Final Conclusion: The writ petition was allowed and the penalty amount was directed to be credited back to the petitioner's Electronic Cash Register.

Ratio Decidendi: Where the relevant delivery place is subsequently regularised in the GST registration and the issue is covered by binding precedent, detention and penalty for transit of the goods cannot be sustained merely for want of prior inclusion of that address.

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