Annexure-F. It is very clear from Annexure-R that there is no difference in the quantity as per the invoice and the quantity as per the PV. In spite of that, they have passed an order under Section 129 of CGST Act and seized the goods. This action of the respondent is without any authority of law. He further contended that before seizing the goods, the respondent has neither given any notice nor an opportunity to explain his case. Hence, the order passed is contrary to the principles of natural justice. He further contended that the Officer who has passed the order Annexure-S is not a competent Authority as defined under the CGST Act and the impugned order passed by the competent authority is without jurisdiction. He further contended that the petitioner has no remedy of appeal under Section 107 of CGST Act on the ground that as per Section 121 of CGST Act in respect of any seizure or retention of the books of accounts and other documents, no appeal is provided. Therefore, the petitioner having no alternative remedy, has approached this Court. Hence, he sought for allowing the writ petition.
