Invoice value governs GST detention where ownership and e-way bill support the transaction; enhanced valuation under Section 129(1)(b) was not sustained.

Detention of goods and vehicle under the GST transit provisions was treated as a matter falling within Section 129, and the stated position was that where ownership is asserted and the movement is supported by invoice and e-way bill, valuation should proceed on the invoice value under Section 129(1)(a). On that basis, the contrary approach under Section 129(1)(b) was not sustained. The goods were directed to be released on invoice value, and the impugned order was quashed.

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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 on the basis of invoice valuation, and whether the impugned order computing the matter under Section 129(1)(b) could be sustained.

Analysis: The challenge arose from detention of goods and vehicle and the consequential order passed under Section 129(3) of the Central Goods and Services Tax Act, 2017 read with Section 20 of the Integrated Goods and Services Tax Act, 2017. The Court accepted the petitioner's position that the dispute was confined to the proceeding under Section 129, and relied on the earlier view that where the petitioner asserts ownership and the transaction is supported by invoice and e-way bill, the authorities cannot enhance valuation while proceeding under Section 129(1)(a). On the record and the binding precedents cited, the Court found no reason to depart from that view.

Conclusion: The goods were directed to be released under Section 129(1)(a) of the Central Goods and Services Tax Act, 2017 on the basis of the invoice value, and the order dated 08.11.2025 was quashed.

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