Summary: The Article provides a detailed GST and E-Way Bill compliance analysis for Bill-To / Ship-To transactions involving intra-state supply in Delhi. It explains that where goods are billed to a registered buyer but delivered to an unregistered project site on the buyer’s instructions, the transaction qualifies as a valid Bill-To / Ship-To transaction under Section 10(1)(b) of the IGST Act, 2017. The supplier must issue the invoice in the buyer’s name with the buyer’s GSTIN while separately mentioning the project site in the “Ship To” section. The analysis also highlights the GSTN Advisory effective from 15 June 2026 making “Ship-To GSTIN” mandatory in E-Way Bills, requiring “URP” to be entered for unregistered delivery locations. It further clarifies that CGST and SGST apply since both supplier and buyer are located in Delhi, and emphasizes strict invoice-EWB matching, valid transport documentation, EWB closure procedures, and compliance safeguards to avoid detention, penalties, or confiscation.
GST & E-WAY BILL COMPLIANCE ANALYSIS
Bill-To / Ship-To Transaction
| Supplier | M/s A — Registered in Delhi |
| Buyer (Bill-To) | M/s B — Interior Designer Firm, Delhi GSTIN |
| Delivery (Ship-To) | Project / Construction Site in Delhi (Unregistered) |
| Tax Applicable | CGST + SGST (Intra-State Supply — both parties in Delhi) |
1. Bill-To / Ship-To Transaction — Qualification Under GST
√ Yes — this is a valid Bill-To / Ship-To transaction under GST law.
In the given scenario, M/s A (Supplier) raises the invoice in the name of M/s B (the buyer/interior designer firm) using M/s B’s Delhi GSTIN and registered office address. However, the goods are physically delivered to M/s B’s project site — a different address without any GST registration. Since the billing address and the physical delivery address differ, this transaction qualifies as a Bill-To Ship-To transaction under GST.
Legal Reference: Section 10(1)(b) of the IGST Act, 2017 — Where goods are delivered by the supplier on the direction of the third party (buyer/M/s B), it shall be deemed that the third party has received the goods. The Place of Supply shall be the principal place of business of the third party (M/s B’s Delhi address), NOT the site where goods are physically delivered.
Transaction Flow
| M/s A
Supplier (Delhi) |
→ | Project Site
Delivery Address (Delhi) |
→ | M/s B
Buyer/Invoice (Delhi) |
2. Tax Invoice — Preparation & Format
Legal Reference: Rule 46 of CGST Rules, 2017 — A tax invoice must contain the name, address, and GSTIN of the recipient. In a Bill-To Ship-To scenario, BOTH ‘Bill To’ and ‘Ship To’ addresses must be clearly and separately mentioned on the invoice face.
The invoice must be raised exclusively in the name of M/s B (the billing party), using their Delhi GSTIN. The ‘Ship To’ field must carry the complete project site address. No GSTIN is required for the site address since it is an unregistered delivery point.
Important: Always include a declaratory statement on the invoice: ‘Goods despatched to project site on instructions of M/s B.’ This establishes the Bill-To Ship-To nature and provides legal protection during transit inspections.
Sample Tax Invoice Structure
| TAX INVOICE
(Original for Recipient) |
|||||||
| Invoice No.: A/2025-26/001
Invoice Date: 25-May-2026 |
Place of Supply: Delhi (07)
Transaction Type: Bill-To Ship-To |
||||||
| SUPPLIER (From)
M/s A [Registered Address, Delhi] GSTIN: 07AAAAA0000A1Z5 PAN: AAAAA0000A |
BILL TO (Recipient)
M/s B — Interior Designer Firm [Registered Office Address] Delhi — 110001 GSTIN: 07BBBBB0000B1Z5 |
||||||
| SHIP TO (Delivery Site)
[Plot No., Street, Locality] Delhi — 110XXX GSTIN: N/A (Unregistered Site) |
|||||||
| HSN Code | Description of Goods | Qty | Rate (₹) | Taxable Value (₹) | GST Rate | ||
| 8302 | Interior Hardware / Fittings (as agreed) | 100 units | 500.00 | 50,000.00 | 18% | ||
| CGST @ 9% | 4,500.00 | ||||||
| SGST @ 9% | 4,500.00 | ||||||
| TOTAL INVOICE VALUE | ₹59,000.00 | ||||||
Declaration: Goods despatched to the project site on the instructions of M/s B (Bill-To party). This supply qualifies as a Bill-To / Ship-To transaction under Section 10(1)(b) of the IGST Act, 2017.
3. E-Way Bill — Detailed Entry Format
CRITICAL UPDATE: GSTN Advisory No. 661 dated 21-May-2026: From 15 June 2026, capturing ‘Ship-To GSTIN’ is MANDATORY in all Bill-To/Ship-To EWB transactions. If the consignee (project site) is unregistered, enter ‘URP’ in the Ship-To GSTIN field. Update your ERP/accounting software immediately.
The E-Way Bill portal has a dedicated ‘Bill To – Ship To’ transaction type. Under the ‘TO’ section: the LEFT side captures Billing To (M/s B’s GSTIN and name), and the RIGHT side captures Ship To (project site address, PIN code, and ‘URP’ as GSTIN).
Legal Reference: Rule 138(1) of CGST Rules, 2017 — EWB Form GST EWB-01, Part A requires GSTIN of recipient (M/s B in Bill-To) and the actual delivery PIN code in Ship-To. Rule 138(3) — E-Way Bill is mandatory for movement of goods with value exceeding ₹50,000.
E-Way Bill Entry Table — Form GST EWB-01 (Part A)
| Field in EWB Portal | What to Enter | Value for This Scenario |
| Transaction Type | Select from dropdown | Bill To – Ship To |
| Supply Type | Select from dropdown | Outward — Taxable |
| Bill-To GSTIN | GSTIN of buyer (M/s B) | 07BBBBB0000B1Z5 |
| Bill-To Legal Name | Registered name of M/s B | M/s B Interior Designer Firm |
| Bill-To Address | Reg. office address of M/s B | [Registered Office, Delhi – 110001] |
| Ship-To GSTIN ★ NEW (Mandatory from 15-Jun-2026) | Enter ‘URP’ for unregistered delivery point | URP |
| Ship-To Address | Complete project site address | [Plot No., Street, Locality, Delhi] |
| Ship-To PIN Code | PIN of project/delivery site | 110XXX |
| Document Type | From dropdown | Tax Invoice |
| Document Number | Invoice number | A/2025-26/001 |
| Document Date | Date of invoice | 25-May-2026 |
| HSN Code | As per invoice | 8302 |
| Taxable Value | Value excl. GST | ₹50,000 |
| CGST Amount | As per invoice | ₹4,500 |
| SGST Amount | As per invoice | ₹4,500 |
| Total Invoice Value | Incl. all taxes | ₹59,000 |
| Vehicle No. / Transporter | Part B — fill before movement | [Vehicle No. / Transporter ID] |
| EWB Validity | Auto-calculated by portal | 1 day (intra-state, up to 200 km) |
New: E-Way Bill Closure Feature (from 15-June-2026)
GSTN has introduced a voluntary E-Way Bill Closure facility. After successful delivery of goods at the project site, the supplier, recipient, transporter, driver, or any authorised person (whose mobile is registered on the EWB portal) can close the EWB. This is separate from cancellation and confirms that delivery is complete.
√ It is advisable to use the EWB Closure feature after each delivery — this reduces future disputes, confirms delivery to tax authorities, and strengthens audit trail.
4. Project Site — GST Registration Requirement
√ The project site does NOT require separate GST registration. It is a delivery location, not a business entity making taxable supplies.
Under GST law, registration is mandatory for persons who make taxable supplies beyond the threshold limit — not for physical locations where goods are received. The project site is simply a delivery point for M/s B’s purchase. M/s B (the registered buyer) takes Input Tax Credit on the invoice issued in their name, regardless of where goods were physically delivered.
Legal Reference: Section 22 of CGST Act, 2017 — Every supplier making a taxable supply is required to register. A project/construction site that does not independently supply goods or services is NOT a supplier and therefore does not require registration.
Important: If M/s B operates from multiple states and a project site is located in a different state from their GST registration state, a separate registration in that state may be required under Section 25(1) of CGST Act. In this scenario, since both parties and the site are in Delhi, no such issue arises.
5. Applicable Tax — CGST + SGST vs. IGST
√ CGST + SGST (Delhi) applies. This is an intra-state supply. IGST does NOT apply.
The determining factor for tax type in a Bill-To Ship-To transaction is the location of the SUPPLIER versus the location of the BUYER (Bill-To party). The Ship-To (delivery site) address is irrelevant for this determination.
| Party | State / Location | Relevance for Tax Determination |
| M/s A (Supplier) | Delhi | YES — Supplier’s location |
| M/s B (Buyer / Bill-To) | Delhi | YES — Place of Supply |
| Project Site (Ship-To) | Delhi | NOT relevant for tax type |
| CONCLUSION | Both supplier and Bill-To party in same state (Delhi) → Intra-state supply → CGST 9% + SGST 9% |
Legal Reference: Section 8 of IGST Act, 2017 read with Section 10(1)(b) of IGST Act — Place of Supply for Bill-To Ship-To transactions is the location of the Bill-To party (M/s B, Delhi). Since Supplier (M/s A, Delhi) and Bill-To (M/s B, Delhi) are in the same state, it is an intra-state supply and CGST + SGST is levied.
6. Compliance Precautions — Transport & Inspection
| Compliance Area | Action Required / Details |
| Documents to carry in vehicle | Driver must carry: (1) Copy of Tax Invoice, and (2) Valid E-Way Bill (printout or QR code). Both are mandatory throughout transit. Absence of either invites detention. |
| EWB validity management | For intra-state Delhi transport: 1 day for up to 200 km. Ensure EWB is valid at the time of delivery. Extend before expiry — window is 8 hours before to 8 hours after expiry. Total extensions capped at 360 days from original date (w.e.f. 01-Jan-2025). |
| Invoice-EWB matching | Invoice number, taxable value, HSN code, and all party details must exactly match between the invoice and the EWB. Any mismatch gives ground for detention under Section 129 of CGST Act. |
| Transaction type selection | Explicitly select ‘Bill To – Ship To’ in the EWB portal. Do NOT generate as a regular/standard transaction — this will cause a mismatch with the invoice and raise red flags during inspection. |
| Ship-To address completeness | The Ship-To address in EWB must include the complete site address with PIN code. Vague descriptions (e.g., ‘construction site’ without street/locality) are risky and may not satisfy inspection requirements. |
| Ship-To GSTIN — NEW (from 15-June-2026) | Mandatorily enter ‘URP’ in the Ship-To GSTIN field for the unregistered project site. Update your ERP/accounting software before 15-June-2026 to comply. |
| EWB Closure (New voluntary feature) | After delivery at the project site, close the EWB via portal/mobile/app to confirm delivery and create a clean audit trail. Available from 15-June-2026. |
| ITC eligibility for M/s B | M/s B can claim full Input Tax Credit since the invoice is in their name with their GSTIN. Ensure M/s A reports the invoice in GSTR-1 and it reflects correctly in M/s B’s GSTR-2B. |
| GSTR-1 reporting by M/s A | M/s A must report the invoice as a B2B supply with M/s B’s GSTIN. Disclose the Ship-To address details if reporting as a Bill-To Ship-To transaction. Do not report as B2C. |
CRITICAL UPDATE: Penalty for non-compliance under Section 122 of CGST Act: Minimum ₹10,000 or tax evaded (whichever is higher) for transporting goods without valid EWB or invoice. Under Section 129, goods and the vehicle may be seized and detained. Under Section 130, goods can be confiscated. Never transport goods worth over ₹50,000 without a valid, matching E-Way Bill.
7. Summary Checklist for M/s A Before Dispatching Goods
√ Invoice raised in name of M/s B with their Delhi GSTIN as ‘Bill To’
√ ‘Ship To’ address (project site — complete address with PIN) shown separately on invoice
√ Declaratory statement on invoice: ‘Goods despatched to site on instructions of M/s B’
√ Tax charged as CGST + SGST (intra-state; both parties in Delhi)
√ HSN code, quantity, value, and tax amounts correctly stated on invoice
√ E-Way Bill generated before movement; transaction type selected as ‘Bill To – Ship To’
√ Bill-To GSTIN = M/s B’s GSTIN; Ship-To GSTIN = ‘URP’ (mandatory from 15-June-2026)
√ Ship-To address in EWB = complete project site address with PIN code
√ EWB values and invoice values match exactly
√ Driver carries both invoice copy and EWB (printout or QR) during transport
√ EWB validity checked; extension planned if delivery is likely to take longer
√ Invoice reported in GSTR-1 as B2B in name of M/s B
√ After delivery: close EWB via portal (voluntary closure feature, from 15-June-2026)
8. Quick Legal Reference Summary
| Legal Provision | Relevance to This Transaction |
| Section 10(1)(b), IGST Act, 2017 | Place of Supply for Bill-To Ship-To transactions = Bill-To party’s location (M/s B, Delhi) |
| Section 8, IGST Act, 2017 | Intra-state supply when Supplier and Recipient are in same state → CGST + SGST |
| Rule 46, CGST Rules, 2017 | Tax invoice must mention both Bill-To and Ship-To addresses in Bill-To Ship-To scenarios |
| Rule 138(1), CGST Rules, 2017 | E-Way Bill (Form GST EWB-01) mandatory for goods exceeding ₹50,000 in value |
| Section 22, CGST Act, 2017 | Registration required for suppliers, not for delivery locations (project sites) |
| Section 129, CGST Act, 2017 | Detention and release of goods transported without proper documents/EWB |
| Section 122, CGST Act, 2017 | Penalty for non-compliance: minimum ₹10,000 or tax evaded |
| GSTN Advisory No. 661, 21-May-2026 | Mandatory Ship-To GSTIN (‘URP’ for unregistered) in EWB from 15-June-2026; EWB Closure feature introduced |
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Disclaimer: This document is prepared for guidance and educational purposes based on GST law provisions and GSTN advisories available as of May 2026. It does not constitute legal advice. Taxpayers are advised to consult their CA/Tax Advisor for specific transaction-level compliance. Laws and advisories may change; please verify current notifications before relying on this document.
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