Generation of EWB where the principal supply is Supply of services

[Guest]

GSTN has issued an advisory on 16-09-2021, which states that

' In cases where along with the principal supply of service, movement of some goods is also involved, e-way bill may be generated. Such situations may arise in cases of supply of services like printing services, works contract services, catering services, pandal or shamiana services, etc. In such cases, e-way bill may be generated by entering the details of HSN code of the goods, along with SAC (Service Accounting Code) of services involved. '

My query is,

1. Is this applicable for Job Work transactions also ?

2. If it is applicable to Job Work transactions also, how can one show both HSN & SAC in 1 E-Way Bill in case of Jobwork Transaction. Because while generating E-Way Bill when we select

a) Transaction Sub Type as Supply, in Document Type we get option for Tax Invoice, which do not contain HSN &

b) when we select Transaction Sub Type as Job Work, in Document Type we get option for Delivery Challan, which do not contain SAC.

[Shilpi Jain]

If you read the advisory it says EWB MAY be generated with HSN and SAC.. It is pretty absurd. Why would anyone want to increase the burden to disclose both HSN and SAC.

It would have been a relief if they would have mentioned that SAC can be mentioned in place of HSN so that the industry is not burdened with identification of HSN of the goods.

[Shilpi Jain]

Also one more aspect to this is that there is nothing called SAC under GST. It is all HSN only for goods as well as services.

[KASTURI SETHI]

Job-work is service under Chapter/Heading No. 9988. Job-work is done on goods so Chapter/Heading/Sub-heading No. is also to be mentioned.

Chapters 1-98 of Customs Tariff Act (as made applicable to GST Acts) stands for goods and Chapter 99 stands for all services.Clear-cut differentiation between both (goods and services) HSN is also referred to all chapters from 1 to 99.

The word, 'SAC' was in force in pre-GST era. Now Chapter/Heading/Sub-heading No. for both goods and services.

[Ganeshan Kalyani]

In case of printing services, works contract services , both goods and services are in one transaction. But in case of job work, goods is returned back by job worker - this is one transaction and job worker raise tax invoice for service of job work rendered by him - this is another transaction. Both are separate. So, e-way bill will be applicable on goods returned by job worker and for job work service invoice e-way bill will not be required. Hence, this instruction is not applicable to job work.

AI Summary

E-way bill generation for service-led supplies where goods move may require recording both goods and service codes for compliance. E-way bill generation is permitted for principal supplies of services when movement of goods occurs; GSTN allows entering the goods' HSN along with the service accounting code. The advisory covers mixed transactions (e.g., printing, works contracts) but raises practical issues for job-work, where movement of goods and the separate service invoice may make recording both codes in one e-way bill impracticable.