SHIP TO GSTN NOT MENTIONED ON INVOICE

[HITESH DEDHIA]

As per CGST Rule 46 in case of Bill to Ship to Transaction,

* Name, Address & GSTN of Bill to Party Required

* Only Address of Ship to Party is required (in RULE 46 there is no Requirement of GSTN of Ship to Party)

* GST officer During Transit is asking for penalty 200% for not mentioning GSTN of Ship to Party.

Issue:

1. Whether GSTN of Ship to Party is mandatory.

2. Customer (Bill to Party) is asking to mention his name on Ship to Party Column and C/o Name of Ship to Party and address of Ship to Party.

3. If we are not mentioning GSTN of Ship to Party in software then on E INVOICE it shows URP. (Un Registered Person). GST officer during transit having objection on URP (How big Companies are URP - asking supplier for concealing information.

Any Solution on Above

Thanks.

[Amit Agrawal]

You should mention GSTN of your customer (Bill to Party) along-with his name with delivery as 'Ç/o Ship To Party with address of Ship to Party' as 'Recipient'.

In other words, recipient & GSTN will be one & same at both places (Bill to Party / Buyer as well as Ship To Party / Consignee) but with have difference addresses as buyer & consignee.

For past period where objection is raised while goods were in transit & officer is not convinced with your explanation, you need to defend yourself legally by taking professional help.

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

[Amit Agrawal]

W.r.t. Rule 46 referred by the querist, kindly note the followings:

A. Sub-rule 3 indeed requires GSTN of the recipient if registered.

B. Sub-rule 4 & 5 deals with a situation where recipient is unregistered.

C. In subject query, "recipient" (as per Section 2 (93) (a) of the CGST Act, 2017) is 'Buyer / Bill to Party' of the goods and not the consignee / Ship to Party per se. And such recipient is indeed registered (irrespective of status of Ship To Party, whether registered or not).

D. In other words, sub-rule 3 of Rule 46 is applicable and not sub-rule 4 or 5 in given situation.

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

[Amit Agrawal]

Please read as 'serial number (d), (e) & (f)' respectively of Rule 46, instead of 'sub-rule (3), (4) & (5)' of rule 46 at various places in my above post. My apology for the inconvenience caused!

[Manimaran nagaraj]

SHIP TO GSTN NOT MENTIONED ON INVOICE, Goods and Services Tax - GST

AI Summary

Recipient GSTIN requirement: include the buyer's GSTIN as recipient on invoices; ship-to GSTIN is not mandatory.
Rule 46 requires the GSTIN of the recipient when the recipient is registered; in bill-to/ship-to arrangements the recipient is the bill-to/buyer, so the buyer's GSTIN must appear on the tax invoice while the consignee's address may be shown separately as the ship-to location. If the consignee is unregistered, specific Rule 46 provisions for unregistered recipients apply, but they do not remove the obligation to record the registered buyer's GSTIN; omission can produce an unregistered indicator on e invoices and may trigger transit inspection objections that require defence.