Announcement Details
Effective February 11, 2025, the E-Way Bill (EWB) system has been updated to allow unregistered dealers to enroll and generate e-Way Bills, as per Notification No. 12/2024 dated July 10, 2024. This initiative aims to streamline the transportation of goods by unregistered persons, ensuring compliance with the Central Goods and Services Tax (CGST) Act, 2017.
Enrolment Process for Unregistered Dealers
Unregistered dealers involved in the movement of goods can now generate e-Way Bills by enrolling on the EWB portal and obtaining a unique Enrolment ID. This ID serves as an alternative to the Supplier or Recipient GSTIN during e-Way Bill generation.
Steps to Enroll Using Form ENR-03:
1. Accessing ENR-03:
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- Navigate to the EWB portal and select “Registration” from the main menu.
- Choose the “Enrolment for Transporters/Unregistered Persons” option.
2. Completing the ENR-03 Form:
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- Select your state and enter your PAN details for verification.
- Specify the type of enrolment and provide address details.
- Enter a mobile number, which will be verified via OTP.
3. Creating Login Credentials:
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- Create a username, check its availability, and set a password.
- Upon successful submission, a 15-character Enrolment ID will be generated and displayed.
4. Generating an e-Way Bill:
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- Log in to the EWB portal using your registered credentials.
- Select the “Generate New” option; your Enrolment ID will auto-populate as the Supplier/Recipient.
- Enter other relevant details to generate the e-Way Bill.
Legal Framework
According to Rule 138 of the CGST Rules, 2017, every registered person causing the movement of goods worth more than ₹50,000 must furnish information before commencing such movement. This rule has been extended to unregistered persons, requiring them to generate e-Way Bills by enrolling on the common portal using Form GST ENR-03.
Comparison: Unregistered vs. Registered Dealers
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Process:
- Registered Dealers: Use their GSTIN to generate e-Way Bills.
- Unregistered Dealers: Must enroll using Form ENR-03 to obtain an Enrolment ID for e-Way Bill generation.
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Penalties:
- Both registered and unregistered dealers are subject to penalties for non-compliance. However, as seen in the aforementioned case, penalties for procedural lapses may be contested if deemed disproportionate.
Example Scenario
An unregistered furniture supplier in Gujarat intends to transport goods worth ₹70,000 to a retailer in Maharashtra. Prior to February 11, 2025, the supplier faced challenges in generating an e-Way Bill due to the lack of GSTIN. With the new system, the supplier can now:
1. Enroll on the EWB portal using Form ENR-03 to obtain an Enrolment ID.
2. Use this Enrolment ID to generate the required e-Way Bill, ensuring compliance during transportation.
This development simplifies the process for unregistered dealers, promoting smoother interstate commerce and adherence to GST regulations.
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