SUPER TECK INDUSTRIE vs THE COMMISSIONER OF STATE GST, Deputy CommissionerII Legal Cell O/o The Commissioner State GST Department
- Court
- GST Appellate Tribunal
GOODS AND SERVICES TAX APPELLATE TRIBUNAL
ERNAKULAM BENCH
5TH FLOOR, CR BUILDING, CGST HEADQUARTERS, I S PRESS ROAD,
ERNAKULAM - 682018
APPEAL NO.APL/ 44/ERN/2026
[arising out of OIA No. GSTA 59/2021 dated 30.12.2021 passed by the Joint Commissioner
(Appeals), State GST, Palakkad]
SUPER TECK INDUSTRIES ............. Appellant
Versus
THE COMMISSIONER OF STATE GST,
THIRUVANANTHAPURAM
......... Respondent
For Appellant For Respondent
K Ramya, Advocate Anil Gopinath, AR
CORAM: Hon’ble Shri Subramanya Rayaprol, Vice-President
Hon’ble Shri Ramamoorthi Sriram, Member (Technical)
………………………………………………………………………………………………….
FINAL ORDER NO: 25/EKM/KERALAM/2026
Date of Hearing: 25-9-2026
Date of Order: 13-11-2026
Per: Subramanya Rayaprol, Vice-President
1.0 Ms K Ramya, Ld Advocate appeared for the appellant and Mr Anil Gopinath,
Ld Joint Commissioner, appeared as AR for the Respondent.
2.0 Ld Advocate appearing for the appellant submits that the appellant is located in
Tamil Nadu and has a GSTIN 33AAPFS6287G1ZP. The brief issue is that the
appellant had supplied 200 Nos. of Crompton Owe 121 PHZ34 1HP Open Well Pumps
to M/s. Crompton Greaves Consumer Electronics, Kochi vide Tax Invoice No.
4732/2020-21 dated 10.02.2021, accompanied by a valid E-way Bill No.
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511239573431 dated 10.02.2021. On interception of the transport vehicle on
11.02.2021, physical verification in Form MOV-04 has been issued to the appellant,
wherein, it has been confirmed that there was no discrepancy whatsoever between
the goods physically verified and the description/quantity reflected in the
accompanying Tax Invoice and E-way Bill. The only discrepancy noticed was that
there was no e-invoice along with the goods. The MOV-06 for detention of vehicle and
goods was issued on 11-2-2021, and subsequently released on bond and bank
guarantee. Further MOV-07 was issued on 11-2-2021 and the MOV-09 was issued on
16-4-2021 to the appellant in the name of Super Teck Industries, Coimbatore, GSTIN
33AAPFS6287G1ZP. She further submits that the goods accompanied regular tax
invoice containing all details, but e-invoice was prepared the next day, on 11-2-2021,
and submitted to the State Tax Authority. She submits that there was no intention to
evade any tax and they have already paid entire tax amount and also filed GST
Returns. She prays that the appeals may kindly be allowed and penalty may be set
aside as there is no intention to evade any tax.
3.0 Ld AR for the respondent reiterates the findings in the order of the JC (Appeals),
and submits that based on their turnover, the appellant was mandatorily required to
prepare an e-invoice, and cannot be overlooked, because the e-invoice was prepared
by them only after interception and issuance of detention order in MOV-06. If the goods
were not intercepted, they would have never prepared the e-invoice and it would not
have come on record, which would have resulted in tax evasion. He has also made a
written submission dated 30-9-2026 in support of the impugned order of detention and
penalty, wherein he has interalia submitted that the Assistant State Tax Officer,
Special Squad, Kerala State GST Department Palakkad during the course of vehicle
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checking intercepted a conveyance bearing registration No KL-09-J-5072 on
11/02/2021 at 05.02 A.M. at Walayar Palakkad. The goods in movement was
inspected by the intercepting officer and it was observed that the vehicle was loaded
with Open well Pump sets. The transporting documents accompanied were verified by
the proper officer. On verification of documents it was found that the appellant was
coming under the class of taxpayer’s with aggregate turnover more than 100 Crores.
E-invoice is a mandatory form from January 1, 2021 as per Notification No. 88/2020-
Central Tax. This is governed by Rule 48(4) of the CGST / KGST Rules, 2017 making
it mandatory for businesses with an aggregate turnover on PAN India basis, exceeding
100Crores. As such it is mandatory that the Invoices had to be uploaded to the Invoice
Registration Portal (IRP) to obtain a unique Invoice Reference Number (IRN) and
digital QR code. As per Rule 48(4) of GST Rules the invoice shall be prepared by such
class of registered persons as may be notified by the Government on the
recommendations of the council, by including such particulars contained in FORM
GST INV-01 after obtaining an Invoice Reference Number by uploading information
contained therein on the Common Goods and Services Tax Electronic Portal in such
manner and subject to such conditions as may be specified in the notification. On
verification it was found that the consignment under transport was not accompanied
by E-invoice. The person in charge of the goods not tendered any soft copy of e-
Invoice nor provided QRN code and IRN embedded physical copy as prescribed under
Rule 46 of GST Rules. As it appeared that there is a contravention of the provisions
of the GST Act and GST Rules, action was initiated under Section 129 of the GST Act.
Hence a statement of the driver was obtained in Form GST MOV-01. It was also
recorded in MOV-01 that no invoice or E-way bill generated to Areekode at the time of
interception of the vehicle. A physical verification was also carried out by issuing order
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in FORM GST MOV-02 wherein it was clearly specified that the consignment is not
supported by e-Invoice. This was also acknowledged by the person in charge of the
vehicle. Accordingly, on completion of physical verification, a report was issued in
MOV-04 under proper acknowledgment. As it appeared that there is contravention of
provisions of the GST Act, the goods and conveyance were required to be detained of
further proceedings. Hence a detention order was issued in FORM GST MOV-06 and
the same was also communicated through driver. Accordingly a notice under Section
129(3) of the GST Act was issued in FORM GST MOV- 07 to show cause why the
proposed tax and penalty should not be payable by the appellant. The appellant was
also afforded an opportunity of being heard on 18/02/2021 at 11 AM before the proper
officer. Meanwhile the appellant submitted reply to MOV-06 on 15/02/2021 wherein he
contented that the goods were transported as per the provision of the GST Act and
Rules. The appellant attributed the failure to generate e-Invoice on technical reasons.
Later the vehicle and goods were provisionally released on 17/02/2021 on furnishing
a Bank Guarantee and a Bond in FORM GST MOV-08 by the appellant. As to complete
the adjudication process the appellant was requested to appear and produce
necessary documents/ evidences substantiating his contentions, if any, on 17/03/2021
before the proper officer. The appellant maintained the same contention that the e-
Invoice could not be generated at the time of transport of goods due to technical
reasons. As the adjudicating proper officer found that there is contravention of Rule
48(4) of GST Rules, and Section 68 read with Rule 138, the applicable tax and penalty
proposed in the show cause notice was confirmed and order of demand of tax and
penalty was issued on 16/04/2021. Against the said order the appellant later preferred
an appeal before the Joint Commissioner of State Tax (Appeals), Palakkad. The
appellate authority rejected the appeal based on the observation that Imposing of
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related tax and equal amount of penalty on the disputed turnover is a statutory
requirement for invoking of Section 129 of the GST Act. Hence, He prays that the
appeals may be rejected and the OIA may be upheld.
4.0 Heard both sides.
5.0 We find that on merits of the case, the issue to be decided is
(i) Whether the State Tax Officer of Keralam State has the jurisdiction to issue show
cause notice, MOV-07 & MOV-09 to a registered person in Tamil Nadu, and
subsequently impose a penalty under Section 129(1), without issuing a TEMP ID of
Keralam State.
(ii) Whether a penalty under Section 129(1) of the CGST/KGST Act, 2017, can be levied
on the recipient of the goods in an inter-state supply, on interception of the vehicle,
when the transporter is carrying proper Tax Invoice and a valid e-way bill, but the
supplier has not prepared an e-invoice on the date of supply.
6.0 On jurisdiction of the Assistant State Tax Officer, we find that the MOV-07
was issued on 11-2-2021 and the MOV-09 was issued on 16-4-2021 to the appellant
in the name of Super Teck Industries, Coimbatore, GSTIN 33AAPFS6287G1ZP by
the Assistant State Tax Officer, Palakkad, Keralam State. Further, a DRC-07, Ref
No. ZD3206210011580 dated 28-6-2021, was issued to the appellant, which is the
summary of the order, was issued by generating a TEMP ID NO.
322100002786TMP. In other words, the ASTO, Palakkad, has exceeded his
jurisdiction, and without generating the TEMP ID has been issuing notices and orders
in the form of MOV-07 and MOV-09 to the registered person of another State i.e.
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Tamil Nadu. Even though the TEMP ID was subsequently generated at the time of
preparation and uploading of the DRC-07 on GST Portal, on 28-6-2021, all such
correspondences and issuance of notice and order under Section 129(3) and MOV-
09, issued between 10-2-2021 till 27-6-2021 by the ASTO to the appellant in Tamil
Nadu, is impermissible and rendered without jurisdiction, and illegal and is liable to
be set aside, ab initio.
7.0 On merits of the case, we find that the appellant had supplied 200 Nos. of
Crompton Owe 121 PHZ34 1HP Open Well Pumps from Coimbatore to M/s.
Crompton Greaves Consumer Electronics, Kochi vide Tax Invoice No. 4732/2020-21
dated 10.02.2021, accompanied by a valid E-way Bill No. 511239573431 dated
10.02.2021 through a truck no. KL-09-J-5072. It is on record that the transport vehicle
was accompanied with a Tax Invoice issued by the supplier and a valid e-way bill,
which is also not disputed. The only dispute is that the supplier who is mandated to
issue e-invoice based on their turnover, has not issued the e-invoice and was not
available at the time of interception of the vehicle. However, the appellant produced
the e-invoice on 11-2-2021, the very next day.
7.1 We find that the vehicle was accompanied with a proper tax invoice and e-way
bill. There was no discrepancy as regards to the quantity and description of goods.
The e-way bill was also valid at the time of interception and no discrepancy noticed
in the e-way bill either. We find that when there is a tax invoice and e-way bill, which
is sufficient for the transporter to demonstrate, the vehicle should have been let go.
As regards the non-issuance of e-invoice, at the time of interception, but
subsequently produced next day, which is also placed on record and not disputed by
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the Revenue, it cannot be a ground for detention of the vehicle and imposing
penalties.
7.2 The appellant has produced the Tax Invoice No, GSTR1, GSTR3B, filed by the
Tamil Nadu unit showing the concerned Invoice No. 4732/2020-21 dated 10.02.2021,
accompanied by a valid E-way Bill No. 511239573431 dated 10.02.2021, showing
Taxable Value: Rs. 780158.80 and IGST : Rs. 93,619.06. The appellant’s own
GSTR2B reflects the same invoice which proves beyond doubt that the transaction
was IGST paid. The obligation on the part of the appellant i.e. recipient of the goods
is limited to carrying the proper Tax Invoice, valid e-way bill, and showing the same
to the officer during checking of the vehicle and its goods.
7.3 As regards, the procedure prescribed for issuance of the e-invoice, there is no
compulsion anywhere in the CGST / KGST Act, to issue the e-invoice for supply of
goods and to carry the same along with the goods. Circular No. 160/16/2021-GST
dated 20-9-2021 has clarified, that there is no requirement of physically carrying the
e-invoice. The CGST/KSGT Act does not prescribe any time lime for issuing the e-
invoice. The GSTN / NIC has been issuing advisories from time to time and had
advised that after issuing the Tax Invoice, and IRN can be generated through the e-
invoicing portal within a period of 30 days from the date of Tax Invoice.
7.4 We find that the Section 31 of the CGST / KGST Act, 2017, prescribes a tax
invoice to be issued by the registered supplier for supplying the taxable goods at the
time of removal of the goods where there is movement of goods. The Section 31 (1)
reads as,
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31. Tax invoice
(1) A registered person supplying taxable goods shall, before or at the time of,-
(a) removal of goods for supply to the recipient, where the supply involves movement
of goods; or
(b) delivery of goods or making available thereof to the recipient, in any other case,
issue a tax invoice showing the description, quantity and value of goods, the tax
charged thereon and such other particulars as may be prescribed:
7.5 Rule 46 of the CGST/KGST Rules gives the format of the Tax Invoices as to
the contents of the Tax Invoice. Rule 48 of the CGST/KGST Act, gives the manner
in which the Tax Invoices are required to be issued. Only for some notified taxpayers
based on their AATO (Aggregate Annual Turn Over), it is mandatory to issue e-
invoices i.e. to generate IRN from the e-invoice portal, by making entries of the Tax
Invoice which is already issued. For such generation of e-Invoice with an IRN, the
NIC/GSTN who are controlling the concerned website/portal have issued advisories
pertaining to the timelines within which such Tax Invoices can be uploaded in the e-
invoice portal for generation of IRN and reporting of the same in the GSTR1 Return.
7.6 We find that the Rule 46 of the CGST/KGST Rules, prescribes that a Tax
Invoice under Section 31 shall be issued by the registered person, who is the supplier
of the goods. Rule 48 (4) & (5) of the CGST/KGST Rules, which prescribes that the
manner in which the Tax Invoice is to be issued, which reads as,
(4) The invoice shall be prepared by such class of registered persons as may be notified
by the Government, on the recommendations of the Council, by including such
particulars contained in FORM GST INV-01 after obtaining an Invoice Reference
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Number by uploading information contained therein on the Common Goods and
Services Tax Electronic Portal in such manner and subject to such conditions and
restrictions as may be specified in the notification.
Provided that the Commissioner may, on the recommendations of the Council, by
notification, exempt a person or a class of registered persons from issuance of invoice
under this sub-rule for a specified period, subject to such conditions and restrictions as
may be specified in the said notification.
7.7 We find that the Section 31 of the CGST/KGST Act, and Rule 46 of the
CGST/KGST Rules, applies only to the registered supplier of goods to prepare the
Tax Invoice / e-Invoice and does not implicate the recipient of the goods, for any such
omission.
7.8 We are also of the opinion for academic purpose, that for any omission in the
preparation of e-invoice under Rule 48(4), it is for the jurisdictional assessment officer
to raise this point during the course of scrutiny or assessment or audit of the
supplier’s records and returns, and take appropriate action as prescribed under GST
Law.
7.9 We find that the penalty is levied for non-preparation of e-invoice by the supplier
of goods, on the recipient of goods under section 129(1) of the CGST/KGST Act.
Section 129(1) reads as,
129. Detention, seizure and release of goods and conveyances in transit
(1) Notwithstanding anything contained in this Act, where any person transports any
goods or stores any goods while they are in transit in contravention of the provisions
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of this Act or the rules made thereunder , all such goods and conveyance used as a
means of transport for carrying the said goods and documents relating to such goods
and conveyance shall be liable to detention or seizure and after detention or seizure,
shall be released,–
(a) on payment of penalty equal to two hundred per cent. of the tax payable on such
goods and, in case of exempted goods, on payment of an amount equal to two per cent.
of the value of goods or twenty-five thousand rupees, whichever is less, where the owner
of the goods comes forward for payment of such penalty;
(b) on payment of penalty equal to fifty per cent. of the value of the goods or two
hundred per cent. of the tax payable on such goods, whichever is higher, and in case of
exempted goods, on payment of an amount equal to five per cent. of the value of goods
or twenty-five thousand rupees, whichever is less, where the owner of the goods does
not come forward for payment of such penalty;
(c) upon furnishing a security equivalent to the amount payable under clause (a) or
clause (b) in such form and manner as may be prescribed:
7.10 We therefore, find that the penalty levied on the recipient of goods, under
Section 129(1) is not at all sustainable as there is no justification for penalizing the
appellant as a recipient of goods, for non-preparation of e-invoice, by the supplier of
goods from another state, even where the Tax Invoice and e-way bill was already
available with the transporter at the time of interception of the vehicle. We find that
only the supplier of the goods can issue an e-invoice for supply of goods, and the
entire burden of issuing an e-invoice is only on the supplier. The imposition of penalty
under Section 129(1), is not at all justified as the appellant, as a recipient of the
goods, has not contravened any Section, including Section 31 of CGST/KGST Act or
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any Rules, including Rule 46 & 48 of CGST/KGST Rules, so as to attract the
penalties under Section 129(1) of CGST/KGST Act.
7.11 Our view is also supported by the judgements of Hon’ble High Court of Kerala
in the case of OSEL DEVICES LIMITED vs Assistant Enforcement Officer cited in
2024 (12) TMI 209 - KERALA HIGH COURT wherein it is held that,
“1. The petitioner has approached this court challenging Ext.P16 order issued under
Section 129 (3) of the CGST / SGST Acts on a short ground. It is the case of the
petitioner that the only defect noted was that an E-invoice was not generated. It is
submitted that the goods were being transported under the cover of E-way Bill as well
as invoices and the Department has no case that there was evasion of tax. It is submitted
that in such circumstances the imposition of penalty of Rs.12,12,120/- under Section
129 of the CGST / SGST Acts is without any legal justification.
. . .
“4. Having heard the learned counsel for the petitioner and the learned Senior
Government Pleader, I am of the view that the issue raised in this writ petition is
covered in favour of the petitioner by the declaration in judgment of this court in T.P.
Metal Roofings (supra), where this court held as follows;
“12. For all the aforesaid reasons, this writ petition is allowed. Ext.P10 is quashed. It
is declared that the provisions of Section 129 of the CGST/SGST Acts do not authorise
the imposition of tax/penalty as contemplated by the provisions of Section 129(1)(a) or
Section 129(1)(b) in cases where only minor discrepancies are noticed and such penalty
can be imposed only for violations which may lead to evasion of tax or where the
transport was with an intent to evade tax or in cases of repeated violations (even of a
minor nature). In other cases, the authorities will impose penalties having due regard
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to the provisions of Sections 122 and 126 of the CGST/SGST Acts. In the facts of the
present case, this Court is of the considered opinion that a penalty of Rs.10,000/-
(Rupees Ten thousand only), as contemplated by the provisions of Section 122(1)(xiv)
of the CGST/SGST Acts can be imposed. On payment of the penalty as directed above,
the Ext.P7 bank guarantee produced by the petitioner shall be released to it. However,
I clarify that this judgment should not be read as holding that every case of expiry of e-
way bill or other discrepancy cannot lead to the initiation and conclusion of
proceedings under Section 129 of the CGST/SGST Acts. Where it is found that such act
was with the intention to evade tax, the Revenue would be justified in initiating and
concluding proceedings under Section 129 of the CGST/SGST Acts leading to
imposition of penalty as contemplated by that provision.”
Accordingly, I overrule the objection raised by the learned Government Pleader that
the petitioner has an effective alternative remedy by way of appeal and quash Ext.P16
order permitting the competent officer to impose penalty in terms of provisions
contained in Section 122 of the CGST / SGST Acts also keeping in mind the provisions
of Section 126 of the CGST / SGST Act. Any amount that has been collected from the
petitioner towards the amount payable by the petitioner in terms of Ext.P16 shall be
refunded to the petitioner after fresh orders are passed by the competent authority.
Writ petition is disposed of as above.”
7.12 Another order of the Hon’ble Allahabad High Court in the case of Nancy Trading
Company Versus State of U.P. And 3 Others cited in 2024 (7) TMI 1303 -
ALLAHABAD HIGH COURT, wherein it is held that,
“. . .
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3. Learned counsel for the petitioner submits that the goods in question were in transit
along with tax invoice, GR's, E waybills. The said goods were detained on the ground
that E Tax Invoice was not generated as per Rule 48 of the Goods and Services Tax
Rules, 2017 (for short the Rules). He further submits that as per Rule 138A of the Rules
there is no provision for carrying E Tax Invoice, hence it was not correct on the part of
the authorities to seize the goods and pass the impugned orders against the petitioner.
He further submits that once the E Waybill was generated, it was within the knowledge
of the authorities about the movement of the goods, hence there was no intention to
avoid payment of tax. He further submits that the authorities have not recorded any
finding with regard to any intention to avoid tax. He further submits that the annual
turn over of the petitioner was much less than the prescribed limit for generating the E
Tax Invoice. He further submits that the dealers who were having annual turn over
above Rs. 20 crores was required to issue E Tax Invoice. He further submits that now
the said limit has been reduced to annual turn over of Rs. 10 crores by notification
dated 1st August, 2022. He further submits that there was a bona fide mistake as the
petitioner was not aware that the said limit has been reduced from Rs. 20 crores to Rs.
10 crores. He prays for allowing the writ petition.
4. Per contra, learned standing counsel submits that Section 129(3) of the UPGST and
CGST Act 2017 empowers the authorities to initiate proceedings and the petitioner is
duty bound to issue tax invoice as per Rule 48 (4) of the Rules which has not been done
in the present case, therefore the action taken by the authorities is justified. He prays
for dismissal of the writ petition.
5. After hearing the learned counsel for the parties, the Court has perused the records.
6. It is admitted that while transiting the goods in question all documents as required
under Rule 138 A of the Rules were accompanying with the goods. Only a technical
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error has been committed by the petitioner for not generating E Tax Invoice before
movement of goods in question. It is not in dispute that Waybill was generated. It is not
the case of the Revenue that there was any discrepancy with regard to quality and
quantity of the goods as mentioned in Tax Invoice, E Waybill as well as GRs
accompanying the goods. The error committed by the petitioner for not generating E
Tax Invoice before movement of goods is a human error. It is also not in dispute that
prior to 1st August, 2022 the dealers who were having annual turn over of more than
Rs. 20 crores was required to issue E Waybill. The said limit has now been reduced
with effect from 1st August, 2022 to Rs. 10 crores, hence there was bona fide mistake
on the part of the petitioner for not generating E Tax Invoice but in absence of any
specific finding with regard to mens rea for evasion of tax, the proceeding under section
129 (3) of the Act should not have been initiated. On the pointed query to the learned
standing counsel as to whether any finding was recorded by the authorities at any stage
with regard to mens rea for evasion of tax has been recorded, the answer was very
fairly in negative.
7. In view of the above, in absence of any finding with regard to mens rea the
proceeding under section 129(3) of the Act cannot be initiated. The impugned order
dated 26.12.2022 passed by respondent no.4 as well as the order dated 26.5.2023
passed by respondent no.3 are hereby quashed. The writ petition is allowed.
8. Any amount deposited in the said proceeding shall be returned back to the petitioner
within a period of one month from the date of production of a certified copy of the
order.”
7.13 We find that the Section 129(1) of the CGST/KGST Act, 2017 cannot be
invoked for imposing penalties for non-issuance of e-invoice under Rule 48(4), when
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a proper Tax Invoice is already issued. Any omission under Rule 48 of the
CGST/KGST Rules is to be monitored by the jurisdictional GST officer during
audit/scrutiny or assessment, of the registered supplier, and take action as per GST
Law.
8.0 We therefore answer the issues raised at para 5.0 as below:
8.1 To answer the issue raised at para 5.0 (i), We find that on jurisdiction, the
Assistant State Tax Officer of Keralam State has NO jurisdiction to issue show cause
notice, MOV-07 & MOV-09 to a registered person in Tamil Nadu, and subsequently
impose a penalty under Section 129(1), without issuing a TEMP ID of Keralam State.
Issuance of TEMP ID after 4 months of issuance of MOV-07 and MOV-09, is totally
illegal, without jurisdiction, is liable to be set aside.
8.2 To answer the issue raised at para 5.0 (ii), we find that a penalty under Section
129(1) of the CGST/KGST Act, 2017, cannot be levied on the recipient of the goods
in an inter-state supply, on interception of the vehicle, when the transporter is carrying
a proper Tax Invoice and a valid e-way bill, but the supplier has not prepared an e-
invoice on the date of supply.
9.0 Accordingly, we pass the following order.
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ORDER
(1) The Assistant State Tax Officer has no jurisdiction to issue a show cause notice
or pass orders imposing penalties to any person outside the State without issuing the
TEMP ID, and therefore, the MOV-07 & MOV-09 issued on 10-2-2021 are rendered
as null & void ab initio.
(2) The Order-in-Appeal No. GSTA 59/2021 dated 30.12.2021 is set aside and the
appeals are allowed with consequential relief.
(Order pronounced in open court)
Rayaprol
Subramanya
Viswanatha
Digitally signed by
Rayaprol Subramanya
Viswanatha
Date: 2026.11.13 19:30:59
+05'30'
Subramanya Rayaprol
Vice-President
Ramamoorthi
Sriram
Digitally signed by
Ramamoorthi Sriram
Date: 2026.11.13 21:00:04
+05'30'
Ramamoorthi Sriram
Member (Technical)
Date: 13-11-2026
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