E-Way Bill: Documents for Conveyance In-Charge and Verification Process
This article outlines the essential documents and compliance requirements for vehicle operators under the GST e-way bill system in India. It covers necessary paperwork, the role of RFID technology, and the verification process authorized officers undertake. The content also includes recent e-way bill updates and discusses the impact of these regulations on both taxpayers and transporters, highlighting the benefits of digital solutions alongside potential challenges for smaller businesses.
The Goods and Services Tax (GST) e-way bill system sets compliance rules for both traders and transporters when moving goods. Specifically, Rules 138A and 138B outline the responsibilities and required compliance for the person in charge of a vehicle. This article details the essential documents to be carried, the significance of Radio Frequency Identification Device (RFID) technology and its compliance aspects, documentation requirements when an e-way bill is not mandatory, the verification process for these documents, and the overall impact of these regulations on taxpayers and transporters.
Recent Updates
August 29, 2021
From May 1, 2021, to August 18, 2021, taxpayers were exempted from e-way bill blocking due to non-filing of GSTR-1 or GSTR-3B for two or more months (for monthly filers) or one or more quarters (for QRMP taxpayers) covering the March 2021 to May 2021 period.
August 4, 2021
E-way bill blocking for non-filing of GSTR-3B resumed from August 15, 2021.
June 1, 2021
- The e-way bill portal clarified that a suspended GSTIN cannot generate an e-way bill. However, a suspended GSTIN can still be a recipient or transporter for a pre-generated e-way bill.
- The transport mode 'Ship' was updated to 'Ship/Road cum Ship'. This allows users to enter a vehicle number for initial road movement and a bill of lading number and date for subsequent ship transport. This modification supports ODC benefits for ship-based movements and enables vehicle detail updates for road legs.
May 18, 2021
The Central Board of Indirect Taxes and Customs (CBIC), through Notification 15/2021-Central Tax, announced that GSTIN blocking for e-way bill generation now only applies to the defaulting supplier's GSTIN, not to defaulting recipients or transporters.
Required Documents for Vehicle In-Charge
The person responsible for the vehicle must carry the following documents:
- The necessary invoice, bill of supply, or delivery challan.
- A copy of the e-way bill, its number, or the e-way bill linked to a Radio Frequency Identification Device (RFID).
Note: An e-way bill linked to RFID is not applicable for goods transported by rail, air, or vessel. Furthermore, for rail transportation, goods will only be released to the consignee upon presentation of a valid e-way bill.
Understanding RFID and Compliance
If a dealer generates an Invoice Reference Number (IRN) by submitting Form GST INV-01, the transporter is not required to carry a physical invoice. Presenting the IRN to the verifying officer is sufficient.
Certain categories of transporters, to be specified by the Commissioner, are mandated to install RFID tags in their vehicles. Once an RFID is installed, the e-way bill must be mapped to it before the journey begins. As of now, the notification specifying these transporters has not been issued.
Documents Required When E-Way Bill is Not Mandatory
In specific situations, yet to be officially notified, the Commissioner may require transporters to carry alternative documents instead of an e-way bill. These may include:
- An invoice, bill of supply, or bill of entry, or
- A Delivery Challan (DC) for goods movement that does not constitute a supply, such as transportation for job work or liquid gas. The DC must be issued in triplicate and comply with the Act's rules.
Document Verification Procedures
An authorized officer has the authority to intercept any vehicle transporting goods. Upon interception, the transporter must present all carried documents for verification, including those mentioned above. For vehicles equipped with embedded RFID, the device will be scanned by a reader, and the linked e-way bill details will be cross-referenced with the goods being transported. An officer may also conduct a physical inspection of the vehicle and its contents. If there is credible information suggesting tax evasion, an officer can perform a physical verification without prior authorization from higher authorities.
Impact on Taxpayers and Transporters
These regulations offer solutions for various stakeholders:
- For traders and transporters who have not yet transitioned to digital methods, the option to carry physical invoices and e-way bills remains. Meanwhile, digitally inclined traders can utilize the IRN and EBN. This flexibility ensures continuity even during technical disruptions.
- However, small-scale transporters might face challenges. The potential cost of installing RFID technology could disrupt their operations and make it difficult to compete with larger transport agencies. While previous government schemes offered subsidies for RFID installation for Micro and Small Enterprises, it remains to be seen if similar assistance will be extended to benefit current dealers.
- Carrying numerous physical invoices and e-way bills can be burdensome for transporters. Even minor delays, like a vehicle breakdown, could lead to difficult situations. Electronic IRNs and e-way bills help alleviate this issue.
- It is crucial to carry valid documents. The person in charge of the conveyance must verify the e-way bill's validity. If goods are transferred to another vehicle, the e-way bill must be updated with the new vehicle's details.
Ultimately, the goal of reducing transit waiting times can be achieved if all parties adopt digital processes, adhere to regulations, and ensure minimal technical issues.