Are e-way bill requirements uniform across India?

With the launch of the nationwide e-way bill system, businesses were expecting uniform rules across all states. It was assumed that the challenges prevalent in the erstwhile regime would not be faced in the GST regime. However, some states have notified parallel rules and procedures for e-way bill generation. A few examples are discussed below.

Parameter Description

Threshold for intra-state movement of goods

  • Bihar has increased the threshold limit to 2,00,000 INR for mandatory generation of e-way bills.
  • Likewise, Delhi, Tamil Nadu, Maharashtra and West Bengal have increased the threshold limit to 1,00,000 INR.
  • On the other hand, Mizoram has reduced the threshold limit to 10,000 INR.
Applicability for certain prescribed goods 
  • In Goa, Gujarat, Chhattisgarh and Madhya Pradesh, e-way bills have to be generated for intra-state movement only in the case of certain prescribed goods.
Intra-district movement
  • Madhya Pradesh and Chhattisgarh have notified that e-way bills are not required for intra-district movement of goods.
Transaction-specific exemptions
  • Delhi has notified that no e-way bill is required in the case of supply by a registered person to an unregistered end customer within the state.
  • West Bengal has provided an exemption from e-way bill generation for intra-state movement of goods where such goods are being sent for job-work or are being returned to the principal, provided such transportation is not for the final delivery of finished goods.

Further, separate guidelines are being issued by each state for e-way bill verification in the course of movement of goods. Recently, the Assam government issued guidelines on the functioning of ‘mobile squads’ that will conduct random checks on vehicles. In the near future, it is expected that other states may follow suit and issue similar amendments/guidelines.

With the above structure, businesses primarily have two options for e-way bill generation and compliances:

Option 1: Generate an e-way bill for each and every movement of goods in all states irrespective of the value, nature of the goods and state-wise notifications. While this would minimise the complexities involved in keeping a track of state-wise updates and safeguard businesses from being non-compliant, the cost of compliances will increase considerably.

Option 2: Keep a track of various updates issued by states in respect of e-way bills and generate the same accordingly. However, keeping track of such updates is a challenging task and, in many cases, the state websites are not updated in a timely manner.

In summary, in order to meet the primary objective of a uniform nationwide e-way bill system, the GST Council should recommend that states implement consistent e-way bill rules.

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Pratik Jain

Pratik Jain

Partner and Leader, Indirect Tax, PwC India

Tel: +91 124 3306507

Dharmesh Panchal

Dharmesh Panchal

Partner and Deputy Leader, Indirect Tax, PwC India

Tel: +91 22 6689 1455

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