Technical transport-document discrepancies cannot justify tax penalties without reliable evidence of deliberate contravention and intent to evade tax.

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....Address and business-particular discrepancies in transport documents do not by themselves establish deliberate contravention or intent to evade tax. Where goods are accompanied by a tax invoice and e-way bill and no quantity or quality discrepancy exists, technical or procedural defects require independent, reliable evidence of evasion before a penalty may be sustained. Penalty proceedings cannot rest on assumptions or unsubstantiated allegations. In the absence of sufficient evidence of intent to evade tax, the penalty and the appellate order sustaining it were set aside.....