In today’s trade and transport, there are numerous cases where a single product is required to be consigned in parts. This means that the goods will be divided into parts and it will sent over to the recipient in instalments. In this article, we would be discussing the treatment of such goods under inter-state transport.
Single Invoice and Delivery Challan
Before we proceed with generation of e-Way bill for multiple conveyance against single invoice, it is important to understand what an invoice is and what is a delivery challan.
By invoice we mean a document which contains the information of the buyer and the seller along with the price of the concerned goods and the date of transfer.
By Delivery Challan we mean a document which contains the details of shipment such as number of goods, type of goods, etc. It usually accompanies the goods while it is being transported. In case the goods are stopped in the middle of transit for inspection purpose, delivery challan is used to verify the goods and its authenticity.
e-Way Bill for multiple conveyance against Single Invoice
Now coming to the main discussion, suppose one single product is being transported through numerous vehicles (say 4 vehicles). Now under this case, there will be only one invoice. However, there will be 4 delivery challans as there are 4 vehicles involved.
The seller of the goods or the buyer of the goods is then required to generated one e-Way bill for every delivery challan. Taking the above example, there would be 4 e-Way bills.
If both, seller and buyer fail to generate e-Way bills then it is the duty of the transporter to generate the e-Way bill. Additionally, the seller needs to generate the complete invoice of goods before the goods are sent in transit. All the vehicles should a delivery challan and e-Way bill, whereas the last vehicle of the consignment should have a delivery challan, e-Way bill and a copy of the invoice.
If the person in charge of the transit fails to provide the required document to the accessing officer, then the goods may be forfeited or penalized.
FAQ Related to the Topic
Q.1 Where multiple invoices are generated on the same customer to be supplied through a same truck. Whether multiple E-way bills must be generated or one e-way bill shall suffice?
Ans: Each invoice/delivery challan shall be considered as one consignment and therefore for each invoice one e-way bill has to be generated irrespective of same or different consignors or consignees.
Q.2 Can multiple invoices be clubbed to generate one e-way bill?
Ans: No, Multiple invoices/delivery challan cannot be clubbed to generate one e-way bill. As provided above each invoice shall be considered as one consignment for the purpose of generating e-way bills. However, after generating all these EWBs, one Consolidated EWB may be prepared by transporter for transportation purpose, if all such goods are going in one vehicle.
Q.3 If goods are supplied in same truck, whether e-way bill would have to be generated even if value of each invoice individually is less than the threshold limit of Rs.50,000/- but overall it crosses Rs.50,000/-?
Ans: Sub Rule (1) of Rule 138 of the CGST Rules require that every registered person who causes movement of goods of consignment value exceeding fifty thousand Rupees is required to generate E-Way bill. Hence, as per this rule, the e-way bill may not be required to be generated if the value of consignment is less than Rs. 50,000/-
Further, sub-rule 7 provides that where consignor or consignee has not generated E-way bill in accordance with provisions of sub-rule (1) and the value of goods carried in the conveyance is more than Rs. 50,000 Thousand Rupees, the transporter shall generate E-Way bill based on the invoice/delivery challan/bill of supply. A plain reading of this sub-rule gives an indication that the E-Way bill is required in case value of consignment in the conveyance exceeds Rs. 50000, even though individual values may be less than Rs. 50,000/-.
However, if one carefully analyse sub-rule 7, it gets attracted only when a consignor/consignee who was required to generate the E-way bill having a value of consignment exceeding Rs. 50,000/- but has not generated (fails to generate) the same. If this view is taken, the e-way bill may not be required for consignment value less than Rs. 50,000/- even if the total value of goods in the conveyance exceeds Rs. 50,000/-.
e.g. if there are 51 consignments of Rs. 1,000 each by different consignors in a truck, the value of all individual consignments is less than Rs. 50,000/- then as per Sub Rule (1) – there is no need to generate E-way bill. If sub-rule 7 is interpreted in such manner that total value of all consignments to be considered, then transporter has to generate the e-way bill for all consignments (of the very small value of Rs. 1,000 each) which may not be the intention of the legislator. It is expected that suitable clarification will be issued by the government to clarify the same to ensure consistent practice across the country.
Q.4 How to generate the e-way bill, if the goods of one invoice are being moved in multiple vehicles simultaneously?
Ans: Where goods pertaining to one invoice are transported in multiple vehicles. For example, Goods transported in semi-knocked down or completely knocked down condition, the e-way bill shall be generated for each of such vehicles based on the delivery challans issued for that portion of the consignment and:
a) the supplier shall issue the complete invoice before dispatch of the first consignment;
b) the supplier shall issue a delivery challan for each of the subsequent consignments, giving reference to the invoice;
c) each consignment shall be accompanied by copies of the corresponding delivery challan along with a duly certified copy of the invoice; and
d) the original copy of the invoice shall be s
Who can generate the e-Way bill?
e-Way bill can be generated by any of the following:
- Seller, provided he is registered with e-Way bill portal
- Buyer, provided he is registered with e-Way bill portal
What documents are required for generating e-Way bill?
The following documents are required for generation of e-Way bill for multiple conveyance against single invoice:
- Invoice of the goods being transported and delivery challans
- Transport details – by road
- Transport details – by rail, ship or air
Have questions? Feel free to ask the same through the comment section.