Invoice-value release of detained goods prevails over enhanced valuation under GST detention provisions.

Detained goods covered by an invoice were required to be released on the invoice value under Section 129(1)(a) of the CGST Act read with Section 20 of the IGST Act, and the authorities could not substitute an enhanced valuation under Section 129(1)(b). The Court applied the settled position that, where the goods are duly covered by invoice, release must be worked out on the invoice value rather than on a higher assessed value. On that basis, the valuation adopted in the impugned order was unsustainable, the order dated 9 August 2025 was quashed, and the goods were directed to be released.

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Issues: Whether detained goods were liable to be released 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 on the invoice value, and whether the authorities could adopt valuation under Section 129(1)(b) of the Central Goods and Services Tax Act, 2017.

Analysis: The petition was confined to the proceedings under Section 129 of the Central Goods and Services Tax Act, 2017. The Court accepted the settled position that where the goods are covered by the invoice, release has to be worked out on the value stated in the invoice and not on an enhanced valuation under Section 129(1)(b). On that basis, the impugned order adopting the higher valuation was not sustainable.

Conclusion: The goods were directed to be released under Section 129(1)(a) on the invoice value, and the order dated 9 August 2025 was quashed. The writ petition was allowed in favour of the petitioners.

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