GSTAT says Bill-to Ship-to Transactions Cannot Be Penalised Merely for Direct Delivery

In Nalwa Steel and Power Limited v. Office of the Commissioner, State Tax, Chhattisgarh, the Tribunal examined the detention of MS TMT bars moving from Raigarh to Indore under a bill-to/ship-to arrangement. The invoices identified Jindal Steel and Power Limited as the billed purchaser and Gupta and Sons as the consignee, while the onward invoices documented the subsequent supply. Finding the invoice chain, e-way bills, correspondence and factory-gate records consistent with the transaction, the Tribunal held that the requirements of the bill-to/ship-to arrangement had been met. It set aside the penalty of ₹6,41,540 under Section 129 and allowed the appeal with consequential relief.