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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.

Manufacturing client faces e-way bill challenges; Rule 55 CGST 2017 clarifies no reconciliation needed, just explanations. A client involved in the manufacturing of liquid gas faces challenges in reconciling the provisional quantities listed on e-way bills with the actual quantities invoiced upon delivery. Due to the technical nature of liquid gas, the quantity removed from the supplier may differ from the quantity delivered. According to Rule 55 of the CGST Rules, 2017, this discrepancy is common and does not require reconciliation, but rather an explanation when queried. The overall turnover should align between tax invoices and e-way bills, though individual transactions may not match due to the unique nature of the goods. (AI Summary)
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Amit Agrawal on Aug 4, 2022

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 on Aug 5, 2022

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.

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