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E-way bill under GST - a note on some transaction

Ganeshan Kalyani
E-way bill compliance: single bill valid for bill-to-ship-to transactions and GSP portals streamline generation and records. E-way bill compliance under GST for bill-to-ship-to and bill-from/dispatch-from transactions: tax is determined by the billed customer's location, a single e-way bill is sufficient for bill-to-ship-to transactions, and an e-way bill may be generated for dispatch-from arrangements. Multiple-vehicle consignments require delivery challans and separate e-way bills per vehicle with the original invoice sent with the last consignment. If consignee refuses delivery, either party may generate an e-way bill to return goods. E-way bills may be generated via the portal or GST Suvidha Providers, which facilitate data import, recordkeeping and reconciliation. (AI Summary)

Bill to Ship To: In bill to ship to transaction the bill is raised on the customer but the material is delivered to another person on the instruction of the customer. In the tax invoice the customer name, address, GSTIN is mentioned under Bill to section and the name, address GSTIN of the another person is mentioned under Ship to section. The rate of tax is determined on the basis of customer State. If the supplier and the customer is in same State then CGST, SGST/UTGST will apply even if the material is dispatched outside the State. And same way if the material is delivered to another person in the same State and then IGST will be charged if the customer to who billed is in another State. In e-way bill form there is field to mention bill to and ship to. There is no need to generate two e-way bill. Only one e-way bill is sufficient. There was confusion that one e-way bill to customer and another e-way bill to another person will have to be generated. Bu it is clarified thru FAQ by the Government that only one e-way bill is sufficient in this bill to ship to transaction.

Bill from dispatch from: In this case the supplier raises an invoice on the customer but the material is to be dispatched from another place to that customer. The supplier may be a agent who procures order from the customer and places order with another person who has that material. But instead of taking material in his custody he instructs that person to send the material to his customer. This is normal business scenario and that is why the Government has given a way out thru FAQ to generate e-way bill in this type of transaction.

More than one e-way bill for one single supply: In case of machinery which cannot be transported in one single vehicle multiple vehicle is arranged to send part by part machinery. In such transaction delivery challan will be prepared for each vehicle and a certified copy of tax invoice will be accompanied and based on delivery challan an e-way bill be generated. Similarly for other vehicle carrying parts of machinery. The original invoice copy to be sent with the last vehicle. The officer should not detain the vehicle by considering the machinery as part of machinery and not the machinery in parts. Because of some persons with wrong intent of evading tax genuine tax persons are also liable to undergo such treatment from the officer. Thus the documents should be properly carried with the vehicle.

Consignee refuses to take delivery of goods: While sending the goods the supplier generates the e-way bill and transports the goods. In some situation due to quality issue or due to miscommunication the customer refuses to take delivery. In such case, either the customer can generate e-way bill and return the goods or if customer does not agree to generate e-way bill then the supplier will have to generate e-way bill and effect the transportation of goods from the customer's premises to the suppliers place.

Generation of e-way bill: The e-way bill can be generated from the e-way bill website or thru GST Suvidha Provider (GSP). The GSP is having a tool and a programme written by them pulls the data from the accounting package to the GSP portal and the taxpayer is only have to quickly cross the information of the invoice populated in e-way bill application form and then click on generate e-way bill. In just a couple of seconds e-way bill is generated. The web portal of the GSP keeps the record of such e-way bill in electronic form for long period of time. It helps to prepare an MIS like how many e-way bill generated, to whom issue etc. It also helps in comparing the e-way bill generated with the outward supply invoices shown in GSTR-1. GSP portal also enables the tax payer to file GSTR-1 and GSTR-3B.

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