E-way bill system is extremely important, both for the government as well as industry. While the government expects the GST collections to significantly improve, the industry would hope that adequate attention is given to administrative issues, including the process to be followed if portal faces technical challenges and vehicle are intercepted for verification. From the industry standpoint, it requires careful planning and changes in IT system to gear up for the compliances as any lapse could lead to supply chain disruption.
A. Introduction of e-way bill
- Nationwide e-way bill system for inter-state movement of goods effective from April 1, 2018
- For intra-state movement of goods, e-way bill system will be introduced by states in a phased manner, but not later than June 1
- As of now, Karnataka and Andhra Pradesh have come out with Notifications providing that e-way bill for intra-state movement shall also be applicable from April 1, 2018
B. Movement of goods for which e-way bill needs to be generated
- Movement in relation to supply of goods
- Movement for any reasons other than supply of goods
- Procurement of goods from an unregistered person, including import of goods
- Effectively, e-way bill needs to be generated for all movement of goods, unless the same has been specifically excluded.
C. Movement of goods for which e-way bill need not be generated
- Goods which have been otherwise exempted from GST
- Specified goods such as jewellery, precious or semi-precious stones, currency, used personal and household effects,LPG
- Goods not covered under GST (alcohol, crude oil, petrol, diesel, natural gas and ATF)
- Transportation of empty cargo containers, movement by a non-motorised conveyance
- Movement under customs bond from an inland container depot or container freight station to a port/airport/air cargo complex/ land custom station or vice-a-versa
D. Threshold limit for generating e-way bill
- E-way bill required where consignment value of taxable goods (along with tax thereon) exceeds `50,000
- No threshold limit in case of inter-state movement of goods from principal manufacturer/ brand owner to job worker
- Where value of an invoice/ challan does not exceed Rs 50,000 but the total consignment value of goods being transported in conveyance exceeds Rs 50,000, the transporter is required to generate e-way bill. However, such requirement is there only in case of inter-state movement of goods.
Further, this provision is not applicable from April 1, 2018, and date for implementation of same shall be notified separately
E. Validity and Cancellation of e-way bill
- Every e-way bill generated is valid for 1 day for every 100 km or part thereof
- Separate validity period of 1 day for every 20kms in case of over-dimensional cargo
- Each day for validity period is to be counted as period expiring at midnight of the day immediately following the date of generation
- In case of expiry due to exceptional circumstances, the validity of existing e-way bill may be extended
- No cancellation of e-way bill possible post expiry of 24 hours from the time of generation
- Cancellation of e-way bill is not possible once the same has been verified in transit
F. Contents of e-way bill
- E-way bill form (GST EWB-01) is divided in two parts – Part A and Part B
- Part A contain details invoice-level information relating to goods such as invoice number and date, GSTIN of supplier and recipient, HSN and value of goods etc.
- Part B contain details relating to transporter of goods such as vehicle number in case of road transport, transport document number.
- Part B not required to be filed in case of intra-state movement within 50kms from the place of consigner to place of transporter for further transportation or from place of transporter to the place of consignee
- Validity of e-way bill starts only when vehicle details in Part B is updated
G. What Businesses need to do in this regard
- Register on the e-way bill portal (www.ewaybillgst.gov.in)
- Map various business transactions and evaluate requirement of generating e-way bill in typical situations such as sales return or rejection, free of cost supply, bill-to ship-to supply, ex-works supply etc.
- Fix up responsibility of persons required to generate, cancel and manage e-way bills
- Obtain transporter ID which can be furnished on the e-way bill form
- Start generating e-way bill from the portal
- Determine changes required in ERP system/ SOPs around e-way bill management
- Make necessary changes in contracts with vendors, customer and transporter
- Take stock of existing way bills