Facts of the Case: In this case, the petitioner was subjected to seizure proceedings and levy of tax and penalty under the GST Act due to an error in the e-way bill accompanying the consignment. The error related to the shipping address, which had been wrongly auto-populated. The authorities alleged that such discrepancy rendered the goods liable for seizure and the petitioner liable to penalty.

The Allahabad High Court held that a mere technical error in the e-way bill regarding the place of shipment cannot justify seizure of goods or imposition of tax and penalty. The Court observed that the proceedings initiated against the petitioner were not legally sustainable.

Aggrieved, the department filed a Special Leave Petition before the Supreme Court.

Issue: Whether a mere technical discrepancy in the auto-populated shipping address in the e-way bill can justify seizure of goods and imposition of tax and penalty under the GST Act.

Held that: The Supreme Court, while condoning the delay in filing, refused to exercise its discretion under Article 136 of the Constitution of India. The Court observed that it was not a fit case to interfere with the judgment of the Allahabad High Court. The Allahabad High Court had applied a consistent line of precedents holding that mere clerical/technical mistakes in e-way bills do not justify penal proceedings.

Accordingly, the Special Leave Petition was dismissed.

The decision thus reaffirms that minor technical errors in e-way bills, particularly auto-populated ones, cannot be the sole ground for initiating punitive proceedings of tax and penalty. It upholds the principle that substance must prevail over form, particularly when goods movement is genuine and tax compliance is otherwise undisputed.

Case Name: Additional Commissioner Grade-2 & Anr. Versus M/s. Zhuzoor Infratech Private Limited dated 08.09.2025

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