Valuation Issues alone were not valid ground for detention of goods in transit in IGST movement

Held: Multiple writ petitions were filed challenging detention, seizure, and confiscation proceedings initiated under Sections 129 and 130 of the GST Acts. In most cases, the goods in transit were accompanied by all statutory documents under Section 68 of the GST Act, except in one case. The authorities intercepted consignments on grounds such as alleged undervaluation, mismatch in description, or discrepancy in quantity. The movement of goods in question largely pertained to inter-State supplies governed by the IGST Act. Assessee questioned both the jurisdiction of State GST authorities and the legality of invoking Sections 129/130 on valuation-related issues. Assessee contend  that Officers under the State GST Act (APGST) lack jurisdiction to initiate proceedings under Sections 129 and 130 in respect of inter-State movement governed by the IGST Act and issues relating to valuation, mismatch, or quantity discrepancies could not form the basis for detention or confiscation under Sections 129 and 130, which were intended to address clear cases of tax evasion. Respondents contended that State officers were cross-empowered under the GST framework (via Section 6 CGST Act and Section 4 IGST Act) and were competent to act as “proper officers.” It was further argued that subsequent clarifications negate the requirement of separate notifications for cross-empowerment. The Court held that Cross-empowerment was not automatic. A State GST officer could act as a “proper officer” under CGST/IGST Acts only where the taxpayer was administratively assigned to the State and the officer was duly authorized. Sections 129 & 130 did not permit adjudication of valuation disputes or minor discrepancies during transit. State officers could act under Sections 129/130 for inter-State transactions only where the State had a revenue stake under Section 17 IGST Act. State officers could not exercise such powers where goods merely transit through the State without originating or terminating there, as the State had no tax entitlement. Undervaluation or price discrepancies alone could not justify detention or confiscation. Such matters must be addressed through assessment proceedings, not transit interception. Authorities must strictly comply with procedural requirements (e.g., inspection reports under Rule 138C) as non-compliance would vitiate proceedings. The impugned detention and confiscation proceedings under Sections 129 and 130 were set aside. The Court held that State authorities lacked jurisdiction in cases of inter-State transit without tax nexus and that valuation-related issues could not justify such coercive action.