📰 𝗔𝗹𝗹𝗮𝗵𝗮𝗯𝗮𝗱 𝗛𝗶𝗴𝗵 𝗖𝗼𝘂𝗿𝘁 𝗥𝘂𝗹𝗶𝗻𝗴: 𝗦𝗲𝗶𝘇𝘂𝗿𝗲 𝗠𝗲𝗺𝗼 𝗤𝘂𝗮𝘀𝗵𝗲𝗱 𝗳𝗼𝗿 𝗟𝗮𝗰𝗸 𝗼𝗳 𝗥𝗲𝗰𝗼𝗿𝗱𝗲𝗱 𝗥𝗲𝗮𝘀𝗼𝗻𝘀 📢 The Court Held: "Without recording reasons for disbelief of the petitioner’s explanation, the seizure memo and penalty cannot be sustained."

🔍 𝗙𝗮𝗰𝘁𝘀: • 𝗖𝗮𝘀𝗲 𝗧𝗶𝘁𝗹𝗲: Rateria Laminators Pvt. Ltd. vs Additional Commissioner Grade 2 • 𝗖𝗮𝘀𝗲 𝗡𝘂𝗺𝗯𝗲𝗿: AHC:163876 • 𝗗𝗮𝘁𝗲: 16-Aug-2023

• 𝗜𝘀𝘀𝘂𝗲: 𝗼 On March 14, 2023, a vehicle carrying goods for Rateria Laminators was intercepted. The e-Way Bill had expired on March 12, 2023. Despite no discrepancies in the quality, quantity, or details of the goods as per invoices and e-Way bills, a tax and penalty were imposed. 𝗼 The petitioner explained the delay was due to a vehicle breakdown and the driver’s illness. However, the authorities failed to record reasons for disbelieving this explanation in the seizure memo.

⚖ 𝗝𝘂𝗱𝗴𝗺𝗲𝗻𝘁: The Allahabad High Court quashed the seizure memo and penalty order, holding that: • Since the authorities did not provide any recorded reasons for doubting the petitioner’s justification, the seizure and penalty orders were legally unsustainable.

📜 𝗞𝗲𝘆 𝗧𝗮𝗸𝗲𝗮𝘄𝗮𝘆: This ruling establishes that authorities must provide clear reasoning for rejecting an assessee’s explanation for delays in e-Way Bill validity. Without such justification, seizure and penalty orders may not be upheld, reinforcing fair treatment in assessments and enforcement. Team GSTpanacea 7503031378