After an aborted attempt in February 2018, on 1 April 2018, the Government of India successfully rolled out an e-way bill portal for tracking the movement of goods under the Goods and Services Tax (GST). Since its implementation, the e-way bill portal has been working well and no technical glitches have been reported.
However, businesses/taxpayers are committing certain mistakes and errors while generating e-way bills through the e-way bill portal. These errors need to be avoided as they could lead to supply chain disruption and penal consequences for businesses/taxpayers.
This article highlights a few of the errors/mistakes committed by businesses/taxpayers while generating e-way bills through the portal.
As per the current e-way bill system, multiple invoices/delivery challans cannot be clubbed to generate one e-way bill. Each invoice/delivery challan shall be considered as one consignment and therefore, for each invoice, one e-way bill has to be generated.
If multiple invoices are issued by the supplier to the recipient—that is, for the movement of goods of more than one invoice of the same consignor and consignee—multiple e-way bills have to be generated. For each invoice, one e-way bill has to be generated, irrespective of whether the same or different consignors or consignees are involved. However, it has been observed that businesses have resorted to the practice of generating one e-way bill by clubbing multiple invoices.
At the time of furnishing a vehicle number in Part-B of the e-way bill, the system expects you to enter the same in a defined format. However, it has been observed that users are not furnishing the required vehicle number in the correct format. For example, if the vehicle number on the registration certificate (RC) is ‘UP 1 345’, the correct format—that is, UP010345—is required to be provided on the e-way bill portal.
It should be noted that the government has issued FAQs clarifying that the vehicle number entered in the e-way bill system is only for information and the GST officer will accept variations as provided in the FAQs with respect to the vehicle number mentioned in the RC.
The current e-way bill system provides users with the option of bulk generation of e-way bills. Through this, a user can upload multiple invoices at the same time and generate multiple e-way bills at one go. To use this bulk generation facility, one has to prepare e-way bill requests through a JSON file. This can be done in two ways: Taxpayers can prepare the same directly through their automated system or they can use an Excel utility available on the e-way bill portal to upload the details of multiple invoices and generate the JSON file. The JSON file is then uploaded on the portal and it automatically generates the required e-way bills.
It has been observed that while using the Excel option for bulk generation, users often reuse a previously used template without completely deleting the previous entries, which often leads to duplication/ incorrect generation of e-way bills.
Instances have been observed where users/businesses have generated e-way bills through a different user ID. For example, in a scenario where a single user has been made responsible for generating e-way bills for more than one place of business, the problem of interchangeable use of IDs has been reported. This has resulted in the generation of e-way bills through incorrect GSTIN.
There is a provision for the extension of the validity period of an e-way bill before and after eight hours of expiry of the validity. It has been observed that the stakeholders responsible for generating e-way bills are not able to make use of this facility due to the lack of tracking mechanisms on the e-way bill portal.
At the time of generation of e-way bills, a user is required to provide a transporter ID or vehicle number. In case third-party transporters are engaged in the transport of goods, a user is required to furnish the transporter ID of such a transporter, pursuant to which the transporter is required to update the vehicle number on the e-way bill portal.
However, it has been observed that users are not furnishing transporter IDs of such third-party transporters and are generating e-way bills by providing only the vehicle numbers of such transporters. As a result, in case of a breakdown, transporters are unable to access the portal and update the vehicle number in the e-way bills.
Under the current framework of the e-way bill system, the consignor or consignee, as a registered person or a transporter of goods, can generate an e-way bill. Further, an unregistered transporter can enrol on the common portal and generate an e-way bill for the movement of goods for his/her business partners.
However, in the absence of any tracking mechanism, businesses have been faced with hurdles in maintaining a track of the e-way bills generated against their GSTINs by their transporters which may not be intended by the consignor.
At the time of generating e-way bills, a user needs to select the type of document and enter the details of the document (such as invoice, bill of supply or delivery challan). It has been observed that users provide incorrect document details while generating e-way bills, thereby increasing the risk of detention of goods or levy of penalty by the inspection authorities. Further, this may pose a challenge subsequently at the time of audit, assessment, etc.
The above errors can easily be minimised with the integration of a technology-based solution in the operations of a business. Adoption of technology is key to meeting the requirements of the e-way bill system and its smooth and effective functioning. In addition, this will enable businesses to link e-way bills with GST returns in the future and avoid reconciliation issues.
Partner and Leader, Indirect Tax, PwC India
Tel: +91 124 3306507
Partner and Deputy Leader, Indirect Tax, PwC India
Tel: +91 22 6689 1455