(English) E-way Bill Notifications – Driving towards a simpler EWB
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On the 8th of March, 2018, the government and the GST Council declared some changes via the latest e-way bill notifications, in a bid to simplify the e-way bill process. With these e-way bill updates, coming in 2 days before the scheduled 26th GST Council meeting on the 10th of March, it can be expected that the government is keen to roll out the e-way bill without any kind of disruption from the 1st of April, 2018 – a date, it is probably planning to declare at the same meeting.
E-way Bill Notifications – What has changed?
Individual Consignment Value to be considered
Given that a single transporter may be transporting multiple consignments for various suppliers, a possible scenario was that the total value being carried by the transporter was more than INR 50,000, although the individual consignments did not exceed INR 50,000. In such a case, an e-way bill was mandated. However, under the new e-way bill updates, there will be no need of the e-way bill, even if the total value of consignments being carried exceeds INR 50,000, as long as the individual consignments are valued at less than INR 50,000. This step is expected to go a long way towards providing relief to e-commerce and courier companies that move packages for delivery.
Change in valuation of consignment for E-way Bill applicability
An e-way bill is to be generated if the value of the consignment is more than INR 50,000 – however, the value used to include both taxable and exempt supplies under GST. Under the e-way bill latest notifications, only the value of taxable supplies i.e. taxable value along with the GST tax amount, will be considered to determine the valuation of the consignment, which in turn will tell you, whether an e-way bill is required or not. Exempt supplies, will be left out of the valuation – which basically means that this change is going to be beneficial to FMCG companies who generally move all kinds of goods together.
Change in the distance norms for E-way Bill applicability
Earlier, e-way bill was not mandatory for goods which are moved within a State or Union Territory, if the distance was less than 10 KM. Also, the transporter was not obligated to furnish the conveyance or vehicle details, if the distance from supplier to transporter, or the distance from transporter to recipient, was less than 10 KM. Under the new e-way bill rules, this limit in distance has been increased to 50 KM – thus making life easier for small businesses.
Option for Transporters to extend validity period of E-way Bill
Earlier, upon the expiry of the validity period of a particular e-way bill, the transporter had to generate a fresh e-way bill. However, now, under exceptional circumstances, especially in the case of trans-shipment, where the vehicle is getting changed, a transporter will have the option to extend the validity period of the e-way bill, and update the vehicle details therein.
Modified time limit for acceptance or rejection of E-way Bill
Earlier, there was a fixed time limit of 72 hours, within which the recipient had to accept or reject an e-way bill which was tagged against him. If no such communication was obtained from the recipient within 72 hours of generation of the e-way bill, it was deemed to be accepted. However, as per the e-way bill latest updates, the recipient has to accept or reject the e-way bill within 72 hours or, by the time the goods are delivered, whichever is earlier. The addition of the clause, will now completely eliminate those scenarios, in which customers would have an option to reject the e-way bill within 72 hours, even if the goods were delivered.
New Dimension to E-way Bill Validity
Earlier, the validity of the e-way bill was determined solely by the distance across which the consignment was being transported. For a distance up to 100 KM, the validity was 1 day, and for every subsequent 100 KM, the validity too was extended by 1 day. However, under the revised e-way bill rules, a new aspect has been added towards understanding the validity of an e-way bill, namely “Over Dimensional Cargo”.
An Over Dimensional Cargo, as per the e-way bill rules, indicates a cargo, which is carried as a single indivisible unit and which exceeds the dimensional limits prescribed as per Central Motor Vehicle Rules. While the validity rules for all goods, which are not under the category of Over Dimensional Cargo, remains the same, the new validity rules for goods, which fall under Over Dimensional Cargo, are as follows:
- Up to 20 KM – 1 day
- For every 20 KM or part thereof thereafter – 1 additional day
Other Changes in E-way Bill Rules
Some other e-way bill notifications and changes which have happened are as follows:
- Railways has been exempted from generating and carrying of e-way bill with the condition that without the production of an e-way bill, railways will not deliver the goods to the recipient. However, railways will be required to carry invoice or delivery challan etc.
- Public conveyance has also been included as a mode of transport and the responsibility of generating the e-way bill in case of movement of goods by public transport would be that of the consignor or consignee
- Registered job worker can also generate the e-way bill in the case of inter-state movement of goods
- E-commerce operator or courier company can also generate e-way bill, on behalf of the consignor, in case the consignment is valued at more than INR 50,000 on authorization by the consignor
- No e-way bill is needed for transit cargo from / to Nepal or Bhutan
- An additional field called “Place of Dispatch” has been added in the e-way bill to capture movement of goods on account of “Bill-To-Ship-To” supply
- Once verified by any tax officer, the same conveyance will not be subject to a second check in any State or Union territory, unless and until, specific information for the same is received
- In case of movement of goods by railways, airways and waterways, the e-way bill can be generated even after commencement of movement of goods
With all these changes coming in, it can be expected that smaller businesses, FMCG, courier and e-commerce companies will surely benefit, when e-way bill sees the light of day. The eagerness of the government to simplify the process is indication enough that e-way bill will become a reality soon. Keep watching our subsequent blogs to know more about what the GSTN finally decides on this matter, post its 26th meeting.
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Author: Pramit Pratim GhoshPramit, who has been with Tally since May 2012, is an integral part of the digital content team. As a member of Tally’s GST centre of excellence, he has written blogs on GST law, impact and opinions - for customer, tax practitioner and student audiences, as well as on generic themes such as - automation, accounting, inventory, business efficiency - for business owners.
Pramit Pratim Ghosh
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