Key E-Way Bill Regulations and Responsibilities for Transporters
This article elucidates crucial e-way bill regulations and the responsibilities of transporters under GST law in India. It details the process for unregistered transporters to obtain a Transporter ID (TRANSIN) and its application in e-way bill generation. The content also covers rules regarding changes in conveyance, transshipment of goods, consolidated e-way bills, and the necessary documents to be carried during transit. Furthermore, it explains the procedures for vehicle inspection and verification, ensuring compliance with GST requirements.
Transporters in India must adhere to the e-way bill regulations outlined by GST law, as they can be held accountable for non-compliance if an e-way bill, required by the supplier or recipient, is not generated.
What is a Transporter ID (TRANSIN) and How to Obtain It?
The Transporter ID, also known as TRANSIN, is a unique 15-digit identification number assigned to transporters not registered under GST. This ID facilitates e-Way Bill generation and is derived from the State code, PAN, and a checksum digit.
Requirements for e-Way Bill Generation by Transporters
All transporters must generate an e-way bill if the value of a single consignment or the cumulative value of all goods in a vehicle exceeds Rs. 50,000. Even unregistered transporters are obligated to generate e-way bills in these situations. The Transporter ID (TRANSIN) concept was introduced to address the absence of a GSTIN for these unregistered entities.
How and When to Use Your Transporter ID (TRANSIN)
Unregistered transporters must use their TRANSIN instead of a GSTIN on all e-way bills. This ID is shared with suppliers or consignors so they can include it on e-way bills, allowing the transporter to update vehicle details for goods movement later.
Step-by-Step Enrollment for Unregistered Transporters on the e-Way Bill Portal
Unregistered transporters receive a Transporter ID upon successful enrollment on the e-Way Bill portal. This enrollment process provides a unique TRANSIN and a specific username for accessing the portal. Below is a detailed, step-by-step guide for unregistered GST transporters to enroll on the e-Way Bill portal:
Step 1: Access the official e-way bill portal. Step 2: On the homepage, locate and click the 'Enrolment for transporters' option found within the Registration tab. Step 3: Fill in the required details in the application across points 1 through 9, then click 'Save'.
Application u/s 35(2) (GST ENR-01) - Detailed Points
Let's review each of the nine points in the 'Application u/s 35(2)' (GST ENR-01) in detail. Fields marked with an asterisk (*) are compulsory.
- Choose your State*.
- Provide the following information: a) Your Name as it appears on your PAN card*. b) Your Trade name, if applicable. c) Your PAN* (The system will validate the PAN for any inconsistencies upon entry and correction before allowing you to proceed).
- Specify the Type of enrolment*: (It's important to note that you must complete points 1 and 2 before proceeding.) Select the appropriate option, such as warehouse, godown, cold storage, or transport service.
- Indicate your Constitution of business*: From the dropdown menu, select the applicable business structure, such as foreign company, partnership firm, proprietorship, private limited company, public limited company, unlimited company, or others (e.g., HUF, AOP, BOI).
- Principal place of business: a) Enter your full address, ensuring all mandatory fields (marked in red) are completed*. b) Contact information: Provide your email address, telephone number, and fax number (if applicable). This email address will be utilized for authentication purposes. c) Nature of premises: For the address provided in (a), indicate whether the building is owned, leased, rented, consent-based, shared, or falls under 'any other' category. Also, include the name of the proprietor or primary individual of the company/firm and their mobile number. The provided mobile number will be used for One-Time Password (OTP) verification.
- Establish Login details*: Create a unique username/user ID and a password. Use the 'Check' function to confirm the availability of your desired username.
- Verification*: Check the declaration box to confirm the accuracy of the information provided, then enter the displayed captcha and click 'Save'.
Outcome: Receiving Your Transporter ID
Outcome: The system will generate and display a 15-digit Transporter ID (TRANSIN). Record this number and share it with your clients.
What to Do if a Transporter Changes the Mode of Conveyance During Transit?
Should a transporter switch the mode of conveyance for goods during transit, they are required to update the e-way bill (Form EWB-01) on the e-way bill portal with the new vehicle details prior to the transfer. An exception applies when goods are transported to a consignee within 50 kilometers in the same State or Union Territory as the transporter's business location; in such cases, updating the conveyance details on the e-way bill is not necessary.
Rules for Transferring Multiple Consignments in a Single Conveyance
When a transporter moves multiple consignments in one vehicle, they must electronically list the serial numbers of individual e-way bills for each consignment on the e-way bill portal. A consolidated e-way bill (Form EWB-02) must be generated before these goods begin their journey.
Managing Goods Transshipment Scenarios
Transshipment refers to altering the transport mode or vehicle during goods transit. The e-way bill portal offers an option for the transporter or the e-way bill generator to update the vehicle number for the consignment being transported. Only the seller or the transporter specified in Part A of the e-way bill can update the vehicle number, and this action can be performed multiple times.
The e-way bill portal also allows for the re-assignment of a different transporter to an e-way bill. After the initially assigned transporter re-assigns the responsibility, the seller loses the ability to make further changes.
Essential Documents for the Person-in-Charge of a Conveyance
The individual responsible for the conveyance must carry specific documents, including the invoice, bill of supply, or delivery challan, along with a physical copy of the e-way bill or its number, potentially linked to an embedded RFID device in the vehicle. The commissioner may also specify alternative documents to be carried, such as a tax invoice, bill of entry, or delivery challan for non-supply transport.
Submitting Tax Invoices and IRN
A registered person can upload a tax invoice (Form INV-1) to the e-way bill portal, receiving an Invoice Reference Number (IRN) valid for 30 days from its upload date. This IRN can serve as proof of verification to an officer, replacing the physical tax invoice. When a registered person uploads an invoice, relevant information for Part A of Form GST INS-1 is automatically populated from GST INV-1.
Furthermore, the commissioner has the authority to mandate certain transporters to use unique RFIDs, which are embedded in the conveyance and linked to the e-way bill before transit.
Vehicle Stops and Document Verification in Transit
Vehicles transporting goods across states or within a state are subject to stops. An authorized officer, appointed by the Commissioner, can halt a consignment to verify its e-way bill. RFID readers will be deployed at key locations to verify goods movement where e-way bills are linked to RFID.
Verification will occur via RFID readers for e-way bills mapped with RFID. Additionally, physical inspections of conveyances may take place.
If there is concrete intelligence regarding tax evasion, an authorized officer can conduct a physical verification even if an initial check has occurred.
Inspection and Verification Procedures for Goods
Officers must record a summary of each goods inspection in transit online, using Part A of GST EWB-03, within 24 hours. The final report, in Part B of GST EWB-03, is due within three days. While goods are typically inspected only once per journey, a vehicle can be stopped again if specific intelligence about tax evasion emerges post-inspection.
Should a vehicle be detained for over 30 minutes, the transporter can upload this detail via Form GST EWB-04 on the common portal.