Inter-unit transfers under the same GST registration are not a supply, and e-way bill value follows the prescribed consignment rule.

Movement of raw material, semi-finished goods, finished goods and capital goods between two units operating under the same GSTIN is an internal transfer without consideration and, because the units are not distinct persons for GST purposes, it does not constitute a supply; no GST is payable on such transfer. For e-way bill purposes, where generation is otherwise required, the value must be determined on the statutory consignment-value basis prescribed for movements other than by way of supply, as reflected in Explanation 2 to Rule 138(1).

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Issues: (i) Whether movement of raw material, semi-finished goods, finished goods and capital goods between two units operating under the same GSTIN constitutes a supply liable to GST; (ii) what value is to be adopted for an e-way bill in respect of such inter-unit movement.

Issue (i): Whether movement of raw material, semi-finished goods, finished goods and capital goods between two units operating under the same GSTIN constitutes a supply liable to GST

Analysis: A person having multiple places of business in the State may operate under a single registration by treating the additional unit as an additional place of business. Where the two units share the same registration, they are not distinct persons for GST purposes. Movement of goods between such units is only an internal transfer without consideration and does not answer the statutory concept of supply. The absence of a separate recipient and the absence of consideration take the transaction outside the charging framework.

Conclusion: Such movement does not constitute a supply and no GST is payable on transfer between the two units working under the same GSTIN.

Issue (ii): What value is to be adopted for an e-way bill in respect of such inter-unit movement

Analysis: E-way bill generation for movement of goods is governed by the valuation mechanism contained in the e-way bill rules. For movements other than by way of supply, the relevant consignment value is the value determined in accordance with the statutory valuation rule and declared in the delivery challan or other accompanying document. Since the transfer is not a taxable supply, the value has to be taken on that statutory basis for e-way bill purposes where generation is otherwise required.

Conclusion: The value must be taken as per Explanation 2 to Rule 138(1) of the GST Rules for the purposes of the e-way bill.

Final Conclusion: Internal transfer of goods between two units under the same GST registration is not taxable as a supply, and the e-way bill value, where applicable, must be determined on the statutory consignnment-value basis.

Ratio Decidendi: Units operating under a single GST registration are not distinct persons, so inter-unit movement without consideration is not a supply; e-way bill valuation for such movement follows the prescribed consignment-value rule.

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