JUDGMENT :

1. The petitioner is a registered dealer under the CGST/SGST Acts and is engaged in the sale of roofing sheets, pipes etc. According to the petitioner, it sold 12,080 Kg of roofing pipes to M/s. Koyasons Building Materials Pvt. Ltd. Palakkad vide Sale Invoice No. TWS/2022/232 dated 23.10.2021 for a total value of Rs.10,46,732/- (Ten lakhs forty-six thousand seven hundred thirty-two only). The goods were then despatched to the purchaser along with the Tax Invoice bearing No. TWS/2022/232 and e-way bill bearing No. 5613 0699 2337 dated 23.10.2021. The vehicle in which the goods were being transported was intercepted by the 1st respondent on 25.10.2021 at 09:59 A.M. at Melmuri, Malappuram, and on the finding that the e-way bill referred to above had expired on 24.10.2021 proceedings were initiated against the petitioner under Section 129 of the CGST/SGST Acts. The proceedings culminated in Ext.P10 order imposing upon the petitioner the liability to pay tax and penalty totalling Rs.3,76,824/- (Three lakhs seventy-six thousand eight hundred twenty-four only).

2. Sri. Hrithwik D. Namboodiri, the learned counsel appearing for the petitioner would submit that there is no finding i