E-Way Bill Detention and Section 129: MOV-01 to MOV-11, Penalties, Deadlines and Release

When goods in transit are stopped, the officer records the driver's statement (MOV-01), may order a physical check (MOV-02, report in MOV-04) and, if he detains the goods, must serve a detention order (MOV-06), issue a notice specifying the penalty (MOV-07) within 7 days and pass an order (MOV-09) within 7 days of serving that notice. Under section 129 the goods are released on payment of a penalty, 200% of the tax where the owner comes forward, or on security for it; if the penalty is not paid within 15 days of the order, the goods or vehicle may be sold. The old 25% pre-deposit for appealing a section 129 order was replaced from 1 October 2025.

Sources checked: 21 October 2026

Facts checked on 21 October 2026 against sections 107 and 129 of the CGST Act and rule 138C of the CGST Rules on the CBIC tax information portal, the Finance Acts 2021 and 2025, CBIC Circular 41/15/2018-GST and the GST Council's press release of 8 October 2026.

Key facts

Point	What applies	Where it comes from
Release on penalty, owner comes forward	200% of tax payable; exempted goods: 2% of value or ₹25,000, whichever is less	Section 129(1)(a)
Release on penalty, owner does not come forward	50% of value or 200% of tax, whichever is higher; exempted goods: 5% of value or ₹25,000, whichever is less	Section 129(1)(b)
Release on security	Security equal to the amount under (a) or (b)	Section 129(1)(c)
Detention needs an order	Served on the person transporting the goods	Section 129(1) proviso
Notice of penalty	Within 7 days of detention	Section 129(3)
Order	Within 7 days of service of the notice; hearing first	Section 129(3), (4)
Payment	Concludes the proceedings	Section 129(5)
Not paid	Goods or conveyance may be sold after 15 days from receipt of the order	Section 129(6)
Conveyance	Released on payment of the penalty or ₹1 lakh, whichever is less	Section 129(6)
Inspection reports	EWB-03 Part A within 24 hours; Part B within 3 days (+ up to 3 days)	Rule 138C
Appeal pre-deposit	25% rule replaced from 1 Oct 2025; confirm the current amount with our expert team	Section 107; Finance Act 2025

What happens when an officer stops my vehicle?

CBIC Circular 41/15/2018-GST sets out the forms used in sequence. The circular predates the 2022 version of section 129, so use it for the form names and order of steps; the time limits come from the current section 129.

• MOV-01: statement of the person in charge of the vehicle.
• MOV-02: order for physical verification of the goods.
• MOV-03: written permission to extend the inspection beyond 3 working days.
• MOV-04: physical verification report, given to the person in charge.
• MOV-05: release order, if nothing is wrong.
• MOV-06: order of detention.

The officer also reports the inspection on the e-way bill portal: a summary in Part A of EWB-03 within 24 hours, and the final report in Part B within 3 days, extendable by up to 3 more days on sufficient cause (rule 138C). A vehicle verified once in a State is not physically verified again in that State unless there is specific information of evasion.

When can goods be detained under section 129?

Section 129 lets the officer detain or seize goods, the vehicle and the documents in transit, but no detention or seizure is allowed without an order served on the person transporting the goods (the proviso to section 129(1)). That order is MOV-06. Ask for a copy, and check that its date matches the day the vehicle was stopped, because the 7-day limits run from detention.

How much penalty does section 129 charge?

The current section 129 (substituted by the Finance Act 2021, in force from 1 January 2022 per the CBIC footnotes) provides for a penalty only, not a separate tax demand:

Situation	Taxable goods	Exempted goods
Owner comes forward	200% of the tax payable	2% of value or ₹25,000, whichever is less
Owner does not come forward	50% of value or 200% of tax, whichever is higher	5% of value or ₹25,000, whichever is less

Instead of paying, the goods can be released on security equal to the same amount (section 129(1)(c)), using the bond in MOV-08. Whether a reduced penalty is possible for a minor documentation error is to be confirmed with our expert team for your case.

What are the deadlines after detention?

1. Within 7 days of detention: the officer issues the notice specifying the penalty (MOV-07).
2. Within 7 days of service of that notice: the officer passes the order (MOV-09), after giving you a hearing (section 129(3), (4)).
3. Within 15 days of receiving the order: pay the penalty, or the goods or vehicle may be sold or otherwise disposed of (section 129(6)). This period may be shortened for perishable or hazardous goods.

Paying the amount concludes the proceedings (section 129(5)). The vehicle itself is released on payment of the penalty or ₹1 lakh, whichever is less.

Do I have to reply to MOV-07, and by when?

The law fixes no reply period for the taxpayer. The 7 days in section 129(3) is the officer's deadline to pass the order after serving the notice, so the window is short in practice. Reply within any time stated in the notice, attach the invoice, e-way bill and transport documents, and ask for the hearing that section 129(4) requires. Our notice deadline calculator and notice decoder help you read the dates.

What are MOV-10 and MOV-11?

These belong to confiscation under section 130, a separate proceeding: MOV-10 is the notice proposing confiscation and MOV-11 the confiscation order. Summaries of MOV-09 and MOV-11 orders are uploaded on the portal in DRC-07 (Circular 41/15/2018-GST).

Can I appeal, and what pre-deposit applies?

You can appeal a MOV-09 order to the appellate authority. On the pre-deposit, the law has changed:

• The Finance Act 2021 (section 116) inserted a proviso: no appeal against a section 129(3) order unless 25% of the penalty is paid.
• The Finance Act 2025 (section 129) substituted that proviso with a different one, with effect from 1 October 2025 according to the CBIC footnote. The 25% rule is no longer in the Act.

The pre-deposit now payable on a section 129 order should be confirmed with our expert team before you file. Older articles and checklists that still say 25% are out of date.

What may change after the 57th GST Council?

On 8 October 2026 the GST Council recommended amending sections 68, 129 and 130 so that goods are intercepted only on specific intelligence with a Joint Commissioner's authorisation, not intercepted in transit States, and not confiscated under section 130 while in transit. These are recommendations only, not law, until the Act is amended and notified.

How do I lower the risk of detention?

Most of it is in the paperwork that travels with the goods: an invoice or delivery challan that matches the goods, and a valid e-way bill with the right vehicle number. Our guide to e-way bill rules for MSMEs covers when one is needed and how long it is valid.

Getting help

Goods held at a checkpoint need a quick, documented reply. Our GST services and GST audit and litigation support teams help with replies to MOV-07, the hearing and any appeal. See also GST notices explained, or book a consultation to ask our expert team.