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Transportation of taxable goods without an E-Way Bill is treated as substantive non-compliance where the bill is generated only after interception and the same lapse recurs. An E-Way Bill forms part of the statutory mechanism for monitoring taxable-goods movement; its absence alongside a manually issued invoice may permit subsequent account manipulation. Post-interception production, combined with repetition in a similar transaction, indicates a deliberate course of conduct and intention to evade tax rather than a technical or procedural breach. On that basis, tax and penalty proceedings were sustained, the first appellate order was set aside, and the Proper Officer's tax and penalty order was restored.
Transportation of taxable goods without an E-Way Bill is treated as substantive non-compliance where the bill is generated only after interception and the same lapse recurs. An E-Way Bill forms part of the statutory mechanism for monitoring taxable-goods movement; its absence alongside a manually issued invoice may permit subsequent account manipulation. Post-interception production, combined with repetition in a similar transaction, indicates a deliberate course of conduct and intention to evade tax rather than a technical or procedural breach. On that basis, tax and penalty proceedings were sustained, the first appellate order was set aside, and the Proper Officer's tax and penalty order was restored.
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