CA Keval Mamania
Under the e-way bill mechanism, significant responsibilities are placed on Transporters for the goods being carried in their conveyance. Following are the responsibilities placed on:
Before starting Movement of Goods
- If the e-way bill is generated neither by Consignor nor by Consignee and the goods are handed over to transporter, then, Transporter must generate e-way bill. However, transporter is not responsible to generate an e-way bill in case of transport by railway, by air or by vessel.
- Any transporter transferring goods from one conveyance to another in the course of transit shall, before such transfer and further movement of goods, update the details of conveyance in the e-way bill on the common portal.However, this is not required where the goods are transported for a distance of less than 10 kms within the State or UT from the place of business of the transporter to the place of business of the final consignee.
- In case where multiple consignments are being transported in one vehicle, transporter may generate consolidated e-way bill in FORM GST EWB-02 which would indicate the serial number of e-way bills generated in respect of each consignment.
- In a scenario where value of goods of different Consignors or Consignees is below Rs. 50,000/- and they had not generated e-way bill but total value of all the consignment in a vehicle is exceeding Rs. 50,000/-, the transporter shall generate FORM GST EWB-01 on the basis of invoice or bill of supply or delivery challan and may also generate a consolidated e-way bill in FORM GST EWB-02.
While in Transport
The person in-charge of conveyance shall carry:
(a) The invoice or bill of supply or delivery challan, as applicable; and
(b) A copy of the e-way bill OR the e-way bill number, either physically or mapped to a Radio Frequency Identification Device embedded on to the conveyance.
Intercept of Conveyance – The authorized officer may intercept any conveyance for verification of e-way bill or physical verification of conveyance. The officer inspection of goods, the proper officer will upload summary report and final report.
Where a vehicle has been intercepted and detained for a period exceeding thirty minutes, the transporter may upload the said information in FORM GST EWB-04. This would ensure that the consignor and consignee are aware of reason for delay in transport and also make concerned officer accountable for his action.
In case the physical verification of goods being transported on any conveyance has been done during transit at one place within the State, no further physical verification of the said conveyance shall be carried out again in the State.
However, physical verification may be carried out only if department has a specific information relating to evasion of tax is made available subsequently.
Apart from above, Commissioner may require class of transporters to embed RFID (Radio Frequency Identification Device) in their conveyance. It is expected that similar to Income Tax Provisions, persons having fleet of less than 10 trucks would be exempted from requirement to embed RFID.
The e-way bill mechanism is expected to be rolled out from October. Though the complexity and unfamiliarity of procedures remains primary concern of transporters, the business organizations armed with right mix of technology and professionals would be in better position to avoid costly errors.
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Disclaimer: This article is for the purpose of general awareness and does not represent professional opinion of the author.