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Bill-To-Ship-To Model (E-Way Bill)

Praveen Nair
e-Way Bill Rules for 'Bill To Ship To' Model Under GST: Invoicing, ITC Eligibility, and Customer Privacy Explained The Central Board of Indirect Taxes and Customs clarified the e-Way Bill requirements for the 'Bill To Ship To' model under the GST regime. In this model, three parties are involved: the buyer (A), the supplier (B), and the recipient (C). Two invoices are necessary: one from B to A and another from A to C. Either A or B can generate the e-Way Bill, but only one is needed. The article also addresses concerns about disclosing end customer details and eligibility for Input Tax Credit (ITC) when goods are directly delivered to the recipient without passing through the buyer. (AI Summary)

A number of representations have been received seeking clarifications in relation to the requirement of e-Way Bill for “Bill To Ship To” model of supplies.

The Central Board of Indirect Taxes and Customs (CBIC) has clarified issues regarding “Bill To Ship To” for e-Way Bill under the Goods and Services Tax ( GST ) regime.

In a typical “Bill To Ship To” model of supply, there are three persons involved in a transaction, namely:

  1. ‘A’ is the person who has ordered ‘B’ to send goods directly to ‘C’.
  2. ‘B’ is the person who is sending goods directly to ‘C’ on behalf of ‘A’.
  3. ‘C’ is the recipient of goods.

In this complete scenario two supplies are involved and accordingly two tax invoices are required to be issued:

Invoice -1, which would be issued by ‘B’ to ‘A’.

Invoice -2 which would be issued by ‘A’ to ‘C’.

Queries have been raised as to who would generate the e-Way Bill for the movement of goods which is taking place from ‘B’ to ‘C’ on behalf of ‘A’.

It is clarified that as per the CGST Rules, 2017 either ‘A’ or ‘B’ can generate the e-Way Bill but it may be noted that only one e-Way Bill is required to be generated as per the following procedure:

Case -1: Where e-Way Bill is generated by ‘B’, the following fields shall be filled in Part A of GST FORM EWB-01:

  • Bill From: In this field details of ‘B’ are supposed to be filled.
  • Dispatch From: This is the place from where goods are actually dispatched. It may be the principal or additional place of business of ‘B’.
  • Bill To: In this field details of ‘A’ are supposed to be filled.
  • Ship To: In this field address of ‘C’ is supposed to be filled.
  • Invoice Details: Details of Invoice-1 are supposed to be filled 

Case -2: Where e-Way Bill is generated by ‘A’, the following fields shall be filled in Part A of GST FORM EWB-01:

  • Bill From: In this field details of ‘A’ are supposed to be filled.
  • Dispatch From: This is the place from where goods are actually dispatched. It may be the principal or additional place of business of ‘B’.
  • Bill To: In this field details of ‘C’ are supposed to be filled.
  • Ship To: In this field address of ‘C’ is supposed to be filled.
  • Invoice Details: Details of Invoice-2 are supposed to be filled.
Goods and Services Tax - GST
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