E-WAY BILL & INVOICE IN CASE OF MOVEMENT OF LIQUID GAS

[ROHIT GOEL]

One of our client is dealing in manufacturing of liquid gas and at the time of removal of liquid gas from the place of supplier the actual quantity of goods is not known so assessee has issued delivery challan mentioning provisional quantity accompanying with e-way bill as per the provisions of rule 55 of CGST Rules, 2017.

However at the time of delivery of goods the actual quantity delivered is different from the provisional quantity mentioned in e-way billl and as such the invoice has been issued on the basis of actual quantity delivered.

You are requested to kindly clarify the procedure to reconcile the values mentioned in e-way bill and invoice.

[Amit Agrawal]

In view of Rule 55 (1), it is my presumptive understanding that the quantity at the time of removal from the place of business of the supplier is not known is only due to technical nature of good involved.

And it is further presumably understood that while entire quantity at the time of removal is indeed actually delivered to intended buyer and also billed therefor, but, difference in quantity as per e-way bill / delivery-challan u/s 55 as compared to tax-invoice is again only due to due to technical nature of good involved and trade practices.

And if so, tax-payer does not have to reconcile the values mentioned in e-way bill and invoice but explain the difference (when asked) on the basis of these technical nature of good involved & trade practices resulting into these differences being a regular feature.

Entire purpose of rule 55 (1) - instead of tax-invoice u/r 46 - is to take care of this scenario only.

These are ex facie views of mine and the same should not be construed as professional advice / suggestion.

[Ganeshan Kalyani]

In total the turnover as per Tax invoice and EWB should be matching. Each transaction may not tie up as the nature of supply is peculiar.

AI Summary

E-way bill and invoice reconciliation: explain technical quantity variances for liquid gas; maintain records to reconcile turnover. When provisional quantity is declared on an e-way bill or delivery challan under Rule 55 because exact quantity at removal cannot be ascertained, the supplier may issue the tax invoice on actual delivered quantity; differences arising from the technical nature of liquid gas and trade practices should be explained when queried. While individual transaction quantities between e-way bills and invoices may diverge, advisors also advise that total turnover as reflected in invoices and e-way bills should be reconcilable, with records maintained to justify variances.