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E-Way Bill: Frequently Asked Questions
Every registered person who causes movement of goods of with value exceeding fifty thousand rupees in relation to supply, or reasons other than supply or inward supply from an unregistered person shall generate e-way bill. It means, the consignor or consignee, as a registered person or a transporter of the goods can generate the e-way bill. The unregistered transporter can enrol on the common portal and generate the e-way bill for the movement of goods for his clients.
The term “Consignment value” as provided under Notification No 3/2018 means value determined as per section 15 of the CGST Act as mentioned on the invoice, bill of supply or delivery challan as the case may be including the applicable tax thereon. Hence, the consignment value is total value as mentioned in the document including tax.
The registered person who causes the movement of goods is responsible for generating the E-way Bill. Hence, primarily liability to raise E-way bill is on consignor/supplier. If consignor fails to generate the e-way bill, it can be generated by transporter also. In case of supply of goods by an unregistered person to registered person, the liability to generate e-way bill is on the recipient (registered person).
Yes, e-way bill is required to be generated whether goods are transported by consignor or consignee in his own vehicle or in a hired one. There are four scenarios • The person causing the movement of goods may raise the e-way bill after furnishing the vehicle no in PART B of form GST EWB-01 if the value is more than 50,000/-. • If the person is the registered person he himself can generate the e-way bill. • If the person is unregistered or end consumer, then he need to get the e-way bill generated from the supplier/consignor based on the invoice issued by him. • Alternatively, he himself can enroll and log in as citizen and generate the e-way bill.
The distance and the validity of e-way bill shall remain the same even when goods are supplied through a multi-modal transport. In order to calculate the validity of e-way bill, the distance to be covered by all the modes combined together must be taken into consideration. The validity provided is as under For distance upto 100 km - One day For every 100 km or part thereof thereafter - One additional day
E-way bill is required to be generated for every movement of goods either in relation to supply or for purpose other than supply. Therefore, e-way bill is generated for every inter or intra-state transfers, where the value on consignment exceeds Rs. 50,000/-
Yes, e-way bill is required to be generated even in case of movement of goods within 10 km. The exemption from updating PART B (vehicle details) is given only in cases of movement of goods from the place of business of consignor to the business of transporter for further movement of such goods. Therefore, in all other cases, e-way bill needs to be generated even if the distance to be covered is less than 10 km. However, if the motorized vehicle is not used for transportation of vehicle, E-way bill is not required.
The user can update PART B (vehicle details) for each change in the vehicle used in the course of movement of the goods up to the destination point. However, the updation must be done within overall validity period of E-way bill. There is no upper cap on the number of updation of vehicle in part B.
There is an option available under the “consolidated EWB” menu as “regenerate CEWB”. The option can be used to change the vehicle number to existing consolidated EWB, without changing the EWBs and generates the new CEWB, which has to be carried with new vehicle. The old one cannot be used then.
E-way bill is an additional document and not a substitute for Tax invoice, delivery challan or any other prescribed document has to be provided.
The e-way bill once generated cannot be modified or edited. Only part B can be updated. Further, even if part A is wrongly entered and submitted then the same cannot be edited later. In such a situation e-way bill generated with wrong information has to be cancelled within 24 hours and generated afresh again.
Consolidated e-way bill contains details of different e-way bill which are moving towards one direction, and these e-way bills will have different validity periods. Hence consolidated E-way bill is not having any independent validity period. However, individual e-way bills in the consolidated e-way bill should reach its destination as per its validity period. The date of invoice / delivery challan is not relevant for determining the beginning time of e-way bill.
Notification no 3/2018 has provided that the E-way bill is not required to be generated for the movement of goods covered under Notification No. 2/2017 central tax (rate). This notification provides for all exempted categories of goods. Hence, there is no need to generate E-way bill when a person is causing movement of exempted category of goods except de-oiled cake. In addition to such exempted goods, E-way bill is not required for following goods: • Non-GST goods i.e. alcoholic liquor for human consumption, petroleum crude, high speed diesel oil, motor spirit, natural gas, aviation turbine fuel, • Goods being transported are not considered as supply under schedule III of CGST Act. • Goods covered under Annexure to rule 138 i.e. LPG, Kerosene, Postal baggage, jewellery, precious metals, stones, currency used and personal household effects etc.
Yes, e-way bill needs to be generated for any movement of goods, hence in case of sales returns the e-way bill needs to be generated and in this situation, e-way bill needs to be generated by that person who is causing movement of such sales return or the transporter who is actually moving the goods. Separate sub-type is being created in the Part A for sales return.
If the consignor or consignee is unregistered taxpayer and not having GSTIN, then user has to enter “URP” (Unregistered person) in corresponding GSTIN column.
No, if a transporter is registered under GST and having a valid GSTIN then such transporter need not again obtain TRAN ID and instead his 15 digits GSTIN can itself be use as TRAN ID. However an unregistered transporter needs to possess a valid TRAN ID in all cases. Unless the 15 digits TRAN ID is not entered the transporter will not be assigned to said e-way bill.
The taxpayer should register the server details of his / her systems through which he wants to generate the e-way bill using the APIs of the e-way bill system.
Where the person generates approx 500 invoices in a day, he may use API to generate e-way bills online. With the help of it, the person who is required to generate e-way bill can link his system with the e-way bill API system and the e-way bill number will get printed at the bottom of its invoice. However, there are some pre-requisites which has to be satisfied to use this facility as referred in the user manual of API.
As e-way bill is interfaced with the GST network, the registration details will be mapped. If any un-registered place of business is captured, it will result in non-compliance. Thus one should amend registration certificate to include all such places. Once additional location is approved in the GSTN Portal, it can be updated on E-Way Bill Portal also.
E-way Bill is required for the movement of the goods within the country. In High Sea Sales, the supply is affected before goods cross the custom frontiers of India, e-way bill is not required. When ultimate buyer receives the goods and files the Bill of Entry he is required to generate E-way Bill for movement from Port to his place.
E-way Bill is required for every movement of the goods. When goods are to be transported from port to warehouse, the e-way bill can be generated against “Bill of Entry” as “Inward Supply” from an unregistered Person and the place of the supplier shall be selected as “other countries”.
Exemption has been provided for the movement of the goods from port, airport, air cargo complex and land custom station to an ICD/CFS for clearance by customs in course of importation. Hence no need to generate e-way bill for movement in between the locations in importation of the goods. In case of exportation, there is no such exemption. In the absence of any exemption, there may be a need to generate e-way bill for movement between ICD/CFS to port for exportation.
E-way bill is required to be generated in case of each movement of goods. In the above situation factory may sent the goods to weighbridge by raising delivery challan on self and the e-way bill needs to be generated for such movement. Once the movement is terminated and goods are received back in the factory, the invoice can be raised and another e-way bill should be generated.
If the accident happens on the road and vehicle is to be changed, the transporter/registered person has to change the details of the vehicle in Part B of the E-way Bill. The E-way bill issued earlier shall continue to be valid till the expiry of the validity period. If the validity of the E-way Bill is expired due to accident of the vehicle or any calamity, then transporter shall generate another E-way Bill after updating the Part B of the E way Bill Form. (It could be falling under the exceptional circumstances when a new ewaybill can be generated).
In case the E-way bill is generated and the movement of the goods doesn’t take place, it has to be cancelled within 24 hours from the time of its generation. If the same is not done, the system will not allow the cancellation by the consignor. In such circumstance, the consignor can request the recipient to reject the e-way bill at his end on the portal within 72 hours of its generation. However, if the time period of 72 hours has also lapsed, there is no mechanism provided to cancel the e-way bill.
In case where goods are transported by job worker, the e-way bill will be generated on the basis of delivery challan not on the basis of the tax invoice issued by the job worker. As we understand that value of the goods moved on the basis of the delivery challan is not to be reported in GSTR-1 and neither there is a mention of the tax invoice issued by the job worker for job work charges in E-way Bill, no data will be auto-populated in GSTR 1.
Rule 138(5A) of CGST Rules 2017 provides that consignor, consignee or transporter may assign e-way bill number to another enrolled or registered transporter for updating the information in the Part B of FORM GST EWB-01 for further movement of the consignment. But once the details have been uploaded in Part B by the transporter, such e-way bill number shall not be allowed to be assigned to any other transporter. Any changes in the Part B can be done only by Transporter ABC.
Where E-way Bill is generated and goods are to be transported from one conveyance to another in the course of transit, the transporter causing further movement of the goods shall be require to update its details in Part B of the e way bill before the movement of the goods. Once the goods are unloaded from the vehicle and loaded in the train, Part B of the E-way bill needs to be updated. Upon further transit of the goods from the train to truck at last mile, Part B must be further updated with the details of the vehicle carrying final goods.
Rule 138(10) provides that the validity of the E-way Bill shall be for the distance mentioned therein for transportation of the goods within the country. This indicates that E-way Bill is required till the goods are within the country not beyond that.
In respect of transport of goods by road, transport document is not a mandatory field for generation of e-way bill. A person may furnish other mandatory details like “Mode of Transport”, “Transport ID” and “Vehicle No” and can generate E-Way Bill. The person causing movement of the goods has to update PART A and PART B.
The following procedure shall be followed:- • The supplier shall issue complete invoice before dispatch of the first consignment • The supplier shall issue delivery challan for each of the subsequent consignments, giving reference to the invoice. • Each consignment shall be accompanied by the copy of corresponding delivery challan along with duly certified copy of invoice • The original copy of the invoice shall be sent along with last assignments. The same procedure shall be followed in case of imports where goods imported in large container is transported through multiple trucks.
If the goods or the vehicle has been detained by the tax officer without proper reason for more than 30 minutes, then transporter can generate “Report of Detention” in form GST EWB-04 giving details of office in charge.
The proper officer as authorised by commissioner or any other person as empowered by him, has the power to make physical verification of conveyance and the e-way bill or e-way bill no in case of all Inter or Intra state movement of goods. Further, in case any goods are moving without e-way bill or where the details are partially declared, the proper officer has proper authority to detain or seize such conveyance or goods and such shall be released after the payment of applicable tax or penalty as provided under section 129 of CGST Act, 2017.
The maximum distance than can be provided in Part A of the E-way bill is 3,000/- Kms in certain cases where distance exceeds 3,000/- Kms registered person is allowed to enter only 3,000/- Kms.
In the above circumstance E-way Bill has to be generated on approximate distance of 3000 kms, the capping on the distance must be suitably increased by the government.
In the above situation, the supplier’s responsibility is to deliver the goods to the buyers place. All risk in transit is borne by the supplier. The transporter is also engaged by the supplier thus movement is caused by the supplier and e-way bill should be generated by the supplier and not recipient. If supplier is unregistered then buyer can generate e-way bill.
As per rule of e-way bill if the movement of goods is caused by a registered person where the value of goods exceeds Rs. 50,000/- e-way bill is required. Proper clarification should be made by the government.
As per annexure to the rule 138 e-way bill is not required for personal and household effects. Hence in the above case E-way bill is not required.
In the E-way bill such situation is not addressed. At present, considering the rule it seems that the transporter may have to generate the separate E-way bill for the movement of goods within each of the tempos based on the document/delivery challan. Government may give the clarification is expected related to it.
AS per section 15 of the CGST Act the consignment value should be the value of the goods including applicable tax thereon. The rent charged is the value of services provided and not the value of goods. Hence, for movement of Goods for rented purpose also the value of goods to be considered as consignment value and not the rent.
The details of the person generating the E-way bill is already pre-filled with address and pin code details. The generator has to enter the counter party details including the address and pin code with approximately distance in kms between the two destination. However, there is no mechanism at present by which the portal will calculate or validate the distance between the parties.
As jewellery is covered in the exempted category of goods in Annexure to Rule 138, there is no need to generate E-Way Bill.
The time limit of 72 hours is merely for the purpose of acceptance of e-way bill. The acceptance of E-way Bill doesn’t mean the acceptance of the goods by the buyer. The buyer can reject the goods if on the receipt, the goods received were not in accordance of the quality parameters or any other reason.
Value of the goods is determined vide section 15 of CGST Act which includes GST on the goods also. Custom duty is includible in the value of goods vide Section 15.Thus custom duty has to be considered for the limit of Rs 50,000/.
Section 122(1)(xiv) of CGST act provides that a taxable person who transports taxable good without specified documents (e-way bill is one specified document) he shall be liable to a penalty of Rs 10,000/- or tax to be avoided whichever is greater.
A consignor of goods can update the details of invoice on portal and can generate IRN which is the unique number assigned to each of the invoices based on the information furnished. Goods can be moved based on IRN without carrying physical copy of the invoice.
EWB is linked to GST common portal for taxpayer registration details. If the taxpayer updates this details on GST Portal, it will be updated in EWB System within day. Otherwise the taxpayer can update through option “Update my GSTIN”
Transport Document Number Indicates Goods Receipt Number or Airway Bill Number or Bill of Lading Number or Railway Receipt Number as per the mode of the transport selected by the tax payer. As per Notification No 3/2018 dated 23rd January 2018 some amendments has been made and Transport Document number has now been added to Part B of the E-way Bill.
In case of goods supplied through “as is where is” basis there is no movement of the goods. Thus, no need to generate E-way Bill.
In this case, there are four Scenarios • When goods to be transported is exempted from GST, no need to generate E-Way Bill. • If goods are taxable goods and the farmer is the registered person he has to generate E-way Bill under “outward” movement. • If the goods are taxable goods and the farmer is not registered and registered recipient is known before commencement of the movement of the goods, the registered recipient needs to generate E-Way Bill • If the goods are taxable goods and the farmer is not registered and registered recipient is not known before commencement of the movement of the goods there may not be any requirement to generate E-way Bill. But the farmer may still generate E-way Bill under “citizen” option
There are 2 Scenarios • If address involved in the above transaction belongs to one legal name/taxpayer as per GSTIN within the state, one e-way bill is to be generated. If “Bill to” is the principal place of Business and “Ship To” is the additional place of business of GSTIN or vice versa in an invoice then one e-way bill is sufficient. • If address involved in the above transaction belongs to different legal name/taxpayer, then two e-way bills have to be generated. One E-way Bill for the first invoice, second e-way bill is from “Bill to” party to “Ship to” party based on the invoice. This is required for the cycle of transactions and taxes will change for inter-state transactions.