E invoice not issued but Easy bill and GST returns filled

Before 01/01/2022 as per Section 129(1)(a) there was Tax and penalty equal to 100% means 100% Tax & 100% penalty. But ..
Section 129 was substituted by Finance Act 2021 and the penalty is now 200% of tax amount .

As such the amount of penalty in both the case is same.So officer as impose the penalty as per Law only.

If the amount is substantial, then you can file a writ petition before the HC as there does not seem to be any intention/evasion of tax.

Ok thank you