28/09/2026
GST Audit Insight: Can absence of toll-plaza records prove that goods were not moved?
A recent GSTAT observation highlights an important principle in GST litigation and audit documentation.
In a Bill-to-Ship-to transaction, goods may be dispatched directly from a location other than the invoicing supplier’s registered premises.
Therefore, the absence of toll-plaza records, by itself, does not establish that the transaction never took place.
The GSTAT considered the complete documentary trail, including:
✅ Tax invoices
✅ E-way bills
✅ Transport documents / bilities
✅ Shipping bills & EGM
✅ Banking records
✅ GST returns
✅ Other transaction and export documents
🔎 Key takeaway for GST practitioners
GST proceedings should not necessarily be decided on the basis of one missing piece of evidence.
The entire documentary trail and the commercial nature of the transaction need to be examined together.
Absence of toll data ≠ automatic proof that goods were never moved.
📌 Case: Pr Commissioner, CGST & CX, Siliguri v. Agarwala’s Bitumex Pvt. Ltd. — Kolkata GSTAT
This is an important point for GST audits, departmental proceedings, ITC/refund matters and export transactions, particularly where goods move under a Bill-to-Ship-to arrangement.
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