Goods Shall Be Released Provisionally If Assessee Demonstrates Inclusion Of Transaction In GSTR-1 Return: Madras High Court

The Madras High Court ruled that goods detained during transit should be released provisionally if the assessee demonstrates the inclusion of the transaction in the GSTR-1 return. The case involved an export order where goods were detained due to the failure to generate an E-Invoice. The assessee argued that the non-generation was due to a technical error and that the E-Invoice was generated the following day. The court directed the assessee to submit a copy of the GSTR-1 report, which would reveal whether the transaction was disclosed as a zero-rated sale. The court emphasized that the delay was a procedural lapse, not an attempt at evasion, and that the goods qualified as a zero-rated sale meant for export. The ruling provided clarity on the provisional release of goods in such cases.