Typographical Error in E-way bill - Should Penalty be Imposed?
As we know that before the movement of goods the e-way bill is required to be generated, non generation of e-way bill can lead to a penalty u/s 129 of CGST Act during the transit. However while generating the e-way bill on the e-way bill portal, sometimes the typographical or clerical errors are made like the error in mentioning the distance, error in mentioning the vehicle number, error in the mentioning invoice number etc. In this article we will make a detailed discussion about whether a penalty can be levied for such typographical errors done without the intention to evade tax? or whether imposing the penalty in such a case is valid under law?
When Penalty under Section 129 is leviable:
Section 129(1) states that where any person transports any goods or stores any goods in contravention of the provisions of this Act or the rules while they are in transit then all such goods and conveyance used as a means of transport for carrying the said goods and documents relating to such goods and conveyance shall be liable to detention or seizure and after detention or seizure, shall be released, on payment of penalty.
Thus from
section 129(1) it is
clear that when the provisions of act or rules for transportation of goods are
violated then the penalty should be levied during transit. If any typological or
clerical error is done unintentionally then the penalty
u/s 129 should not be
leviable subject to the condition that there is no evasion of tax due to this
error.
For example, if any typing error is made in mentioning the distance in the e-way
bill like 25 K.m are shown as 125 k.m. in the e-way bill. However, the valuation
of goods are done properly as per
section 15 of CGST Act 2017 and the
classification of goods are also done properly as per provisions of the Custom
Tariff. Thus there is no tax evasion in this case, hence the penalty
u/s 129
should not be levied in this case.
In other words, typing mistakes on E-way Bill where full and correct tax has
been paid should not lead to detention of goods along with levy of penalty.
The same was also clarified by the CBIC vide Circular No. 64/38/2018 that in case a consignment of goods is accompanied with an invoice or any other specified document and also an e-way bill, proceedings under section 129 of the CGST Act may not be initiated in the following situations:
Spelling mistakes in the name of the consignor or the consignee but the GSTIN is correct;
Error in the pin-code but the address of the consignor and the consignee mentioned is correct, subject to the condition that the error in the PIN code should not have the effect of increasing the validity period of the e-way bill;
Error in the address of the consignee to the extent that the locality and other details of the consignee are correct;
Error in one or two digits of the document number mentioned in the e-way bill;
Error in 4 or 6 digit level of HSN where the first 2 digits of HSN are correct and the rate of tax mentioned is correct;
Error in one or two digits/characters of the vehicle number.
Judicial Pronouncements:
There are various case laws in
which it was held that no penalty can be levied when there is no intention to
evade tax. Some the judgements are summarised as follows;
1. Hindustan Herbal Cosmetics Versus State of UP and others [2024(01)LCX0045]
the facts of the case were that the consignment of goods was intercepted and the
seizure order was passed on the ground that the vehicle number in Part-B of the
e-way bill was incorrect. In the present case, instead of ‘5332’, ‘3552’ was
incorrectly entered into the e-way bill which clearly appears to be a
typographical error. Thus, the court was of the view that imposition of penalty
under Section 129 of the
Act is without jurisdiction and illegal in law and held that a typographical
error in the e-way bill without any further material to substantiate the
intention to evade tax should not lead to imposition of penalty. Thus, impugned
order was quashed and set aside.
2. Sabitha Riyaz Versus Union of India [2018(10)LCX0013]
the facts of the case were that the goods were detained on the ground that in
the e-way bill the distance was shown as 280 Kms. instead of 2800 Kms. The
Kerala High Court held that this is the case of typographical error and
therefore such minor errors do not have serious impact. The distance between
Kerala and Uttarakhand is a matter of record and this can be verified
independently.
3. SL Yadav Cranes Private Limited Versus State of U.P. [2025(03)LCX0088]
wherein the goods were transported with a valid e-way bill and delivery challan.
However, a typographical error in the vehicle number on the e-way bill led to
the penalty. The petitioner argued that the error was minor and did not warrant
a penalty. Despite submitting a reply explaining the mistake and proving
ownership of the goods, the penalty was imposed. The respondent's counsel argued
that the discrepancy in the vehicle number justified the penalty under
Section 129(1)(b) of the
Act. However, the Court referred to the M/s. Halder Enterprises case, which
established that when valid documents are produced, the goods should be treated
as belonging to the owner, and the penalty should not be imposed under
Section 129(1)(b), but
rather under Section 129(1)(a).
Applying this principle, the Court quashed the order, ruling that the penalty
was unjustified. It directed the authorities to release the goods under
Section 129(1)(a) and
allowed the petitioner to pursue further legal remedies for other issues. The
petition was disposed of with these directions.
4. Vishnu Singh Versus State of Up [2025(02)LCX0068]
wherein due to technical mistake, at the time of generating the e-way bill,
tax invoice number has been wrongly mentioned due to human error. The vehicle
along with goods was intercepted and seized on the ground that the different tax
invoice number mentioned in the e-way bill. The Court held that an incorrect
invoice number entered in an e-way bill is a minor human error and should not
result in seizure and penalty when all other accompanying documents are valid.
5. Hawkins Cooker Versus State Of U.P. [2024(02)LCX0310]
in said case the petitioner purchased/stock transferred various parts/raw
materials from outside the state of UP, for being delivered in its factory. In
four out of the 8 E-Way bills, the place of supply was correctly mentioned to be
the factory of the petitioner and in other 4 it has been wrongly mentioned to be
the principal place of business (registered office) of the petitioner. The goods
were intercepted and the memo of detention was issued and subsequently the goods
were seized. The mere technical error committed by the petitioner cannot result
in imposition of such harsh penalty upon the petitioner. Thus, the Court held
that the penalty imposed in this case is without any basis in law and
accordingly, impugned penalty order and the order passed in appeal are quashed
and set aside.
Conclusion: In case of Typographical or clerical errors in e-way bills
the penalty u/s 129 should
not be imposed during transit subject to the condition that there is no
intention to evade tax.
Disclaimer: The information given in this article is solely for
purpose of understanding the law. It is completely based on the interpretation
of the author and cannot be constituted as a legal advise, the author of this
article and Lawcrux team is not responsible for any legal issues if arises on
the basis of the interpretation given above.