For goods detained while accompanied by a tax invoice, penalty...

For goods detained while accompanied by a tax invoice, penalty proceedings fall under section 129(1)(a) where the taxpayer can be regarded as the owner of the goods. Subsequent restoration of GST registration prevents treating the consignor or consignee as bogus or maintaining proceedings under section 129(1)(b) on the basis that the taxpayer was unregistered. The penalty was therefore enforceable under section 129(1)(a), and the orders were modified accordingly.