GST – Allahabad High Court: No penalty for non-updation of destination address as “additional place of business”, as no mismatch in goods or documents accompany e-way bill [Order attached]

In a recent decision by the Allahabad High Court, the detention of goods due to the non-declaration of a destination address, despite having a valid e-way bill, was deemed invalid. The case involved M/s Prostar M Info Systems Ltd., which was transporting goods internally between its units in Noida and Lucknow to fulfill a supply order for TCIL, with the final destination being Lucknow. The goods were accompanied by a valid e-way bill and a delivery challan. However, the vehicle was intercepted, and issues were raised about the delivery challan being unsigned and the destination address not being declared as an additional place of business.
The authorities imposed a penalty under Section 129(3), which was upheld on appeal. The central issue was whether the non-declaration of the destination as an additional place of business justified the detention and penalty, despite the presence of a valid e-way bill. The High Court referred to a State Circular from January 2024, which clarified that the non-declaration of the destination address should not trigger Section 129 penalties. The Court found no intent to evade tax, and the movement of goods was adequately covered by the e-way bill without any discrepancies in the documentation.
Consequently, the High Court quashed the penalty and appellate orders, ruling the detention was unnecessary and lacked a legal basis. The writ petition filed by M/s Prostar M Info Systems Ltd. was allowed, setting a precedent that valid e-way bills sufficiently cover internal goods movement, even if the destination address is not declared as an additional business location.
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29-Nov-2025 13:00:55
In a recent decision by the Allahabad High Court, the detention of goods due to the non-declaration of a destination address, despite having a valid e-way bill, was deemed invalid. The case involved M/s Prostar M Info Systems Ltd., which was transporting goods internally between its units in Noida and Lucknow to fulfill a supply order for TCIL, with the final destination being Lucknow. The goods were accompanied by a valid e-way bill and a delivery challan. However, the vehicle was intercepted, and issues were raised about the delivery challan being unsigned and the destination address not being declared as an additional place of business.
The authorities imposed a penalty under Section 129(3), which was upheld on appeal. The central issue was whether the non-declaration of the destination as an additional place of business justified the detention and penalty, despite the presence of a valid e-way bill. The High Court referred to a State Circular from January 2024, which clarified that the non-declaration of the destination address should not trigger Section 129 penalties. The Court found no intent to evade tax, and the movement of goods was adequately covered by the e-way bill without any discrepancies in the documentation.
Consequently, the High Court quashed the penalty and appellate orders, ruling the detention was unnecessary and lacked a legal basis. The writ petition filed by M/s Prostar M Info Systems Ltd. was allowed, setting a precedent that valid e-way bills sufficiently cover internal goods movement, even if the destination address is not declared as an additional business location.
Parties: M/s Prostar M Info Systems Ltd. V. State of U.P. & Ors.
Order Date: 17 November 2025
Facts –
- Petitioner, a registered entity with units in Noida and Lucknow, moved goods internally for fulfilling a supply to TCIL, destined to a consignee in Lucknow.
- Goods were accompanied by a valid e-way bill (valid upto 21.03.2023) and a delivery challan.
- During movement, delivery challan mentioned petitioner’s own GSTIN as shipping address; e-invoice and corrected invoice uploaded later.
- Vehicle intercepted on 19.12.2023; department alleged that Delivery challan was unsigned, and Destination address not declared as “additional place of business”.
- Penalty under Section 129(3) imposed; appeal dismissed.
Issue –
- Whether non-declaration of destination address as an additional place of business, despite possession of a valid e-way bill and delivery challan, justifies detention and penalty under Section 129?
Order –
- The High Court relied on State Circular dated 17.01.2024, holding that non-declaration of destination address is not a ground for invoking Section 129.
- Valid e-way bill completely covered the movement; no mismatch in goods or documents.
- No finding of intent to evade tax. Thus, Detention was unnecessary and without legal basis.
- Penalty order dated 22.12.2023 and appellate order dated 07.06.2024 were quashed. Writ petition allowed.
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