Amara Raja Batteries Limited Vs State of Madhya Pradesh (Madhya Pradesh High Court)
The Madhya Pradesh High Court dismissed the writ petition filed under Article 226 challenging the imposition of a 100% penalty under Section 129 of the M.P.Goods And Services Tax Act, 2017, arising from a discrepancy in the destination mentioned in an e-way bill. The petitioner, a registered manufacturer of lead-acid batteries with warehouses across India, arranged a branch transfer of goods from its Ahmedabad warehouse to its Jabalpur warehouse on 26.02.2019. While the invoices and consignment notes correctly reflected Jabalpur as the destination and applicable IGST and SGST of ₹2,17,305 were duly paid, the e-way bill erroneously mentioned Indore as the destination.
On 01.03.2019, the transporting vehicle was intercepted by GST authorities near Bhopal, far beyond Indore, revealing a mismatch between the route taken and the destination specified in the e-way bill. The goods and vehicle were detained, and a penalty equal to 100% of the tax paid was imposed and later upheld in departmental appeal. The petitioner argued that the error was purely clerical, without any intent to evade tax, and relied on CBIC circulars permitting leniency for minor mistakes, as well as earlier High Court decisions granting relief in similar situations.
