GSTAT Raipur Sustains IGST Demand on Unexplained Duplicate E-Way Bills: A Comprehensive Analysis of the Sapna Industries Judgment

The Goods and Services Tax Appellate Tribunal (GSTAT), Raipur, recently delivered a significant ruling regarding the evidentiary burden placed on an assessee when multiple e-way bills are generated against a single tax invoice. In the matter of Sapna Industries Vs Commissioner of State Tax (GSTAT Raipur), the Tribunal upheld an appellate order confirming a tax demand, interest, and penalty stemming from unexplained transport records.

This article provides an in-depth summary and legal analysis of the Tribunal’s judgment, exploring the factual matrix, the statutory framework governing e-way bills, the evaluation of judicial precedents, and the critical compliance takeaways for businesses engaged in the inter-state movement of goods.

Introduction and Background of the Dispute

The legal dispute in Sapna Industries Vs Commissioner of State Tax (GSTAT Raipur) pertains to the Financial Year 2018-19. The assessee filed an appeal challenging the Order-in-Appeal dated 27 June 2025, which was passed by the Joint Commissioner (Appeals), State Tax, Raipur. This appellate order had affirmed the initial adjudication order dated 26 April 2024, issued by the Assistant Commissioner, State Tax, Circle-8, Raipur.

As per the adjudication order, the authorities confirmed a total demand of Rs. 1,80,139 against the assessee. This aggregated amount comprised an IGST demand of Rs. 76,500, an interest component of Rs. 83,639, and a penalty of Rs. 20,000. The core issue triggering these proceedings under Section 73 of the Central Goods and Services Tax Act 2017 (read with the corresponding State Act and the Integrated Goods and Services Tax Act 2017) was the generation of two separate e-way bills for identical invoices.

Initially, the show-cause notice issued on 15 January 2024 proposed an IGST demand of approximately Rs. 1,53,001. However, the adjudicating authority ultimately restricted the tax liability to one additional, unaccounted supply component per invoice, quantifying the tax at Rs. 47,208 for the first invoice and Rs. 29,292 for the second.

Factual Matrix of the Transport Discrepancies

The revenue department’s scrutiny of the assessee’s returns and e-way bill data revealed critical anomalies concerning two specific invoices. The department alleged that while the assessee accounted for one outward supply per invoice, the generation of a subsequent, distinct e-way bill for each invoice indicated a secondary, undisclosed movement of goods upon which applicable taxes were evaded.

Anomalies Surrounding Invoice No. 59/2018

For Invoice No. 59/2018, dated 10 May 2018, the declared taxable value was Rs. 2,62,268, attracting an IGST of Rs. 47,208.

• The First E-Way Bill: Generated on 10 May 2018, this document covered an approximate distance of 850 km from Abhanpur/Raipur to Lucknow and carried a validity up to 19 May 2018. The Part-B history of this bill indicated a vehicle update at Allahabad on the evening of 19 May 2018.
• The Second E-Way Bill: Despite the original bill showing no formal extension of validity, a completely fresh Part-A entry was logged on 21 May 2018. Strikingly, this new e-way bill again declared Abhanpur/Raipur as the starting point of dispatch, utilizing the same invoice and goods receipt details.