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How do E-way bill rules impact the Unregistered Persons?

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E-way bill provisions have come into effect from 1st April 2018 for inter-state transactions and in a staggered manner will be rolled out for intra-state transactions by 1st June 2018.
 
The erstwhile physical Way Bills have now become Electronic-Way Bills. It is indeed a step towards Digital India and a transparent tomorrow.
 
As a quick recap, the E-way bill rules requires that for all movement of goods meeting the specified criteria, a unique number is to be obtained from the Government's system and this unique number, referred to as E-way Bill Number needs to be carried along with the consignment. In most of the cases, the movement of goods can be commenced only after generation of an E-way Bill Number. Read our article '6 Things You Need to Know about e-Way Bill' to know more about E-way bill. 
 
Typically, the person initiating the movement of goods is responsible for generating the E-way Bill Number. However, the transporters are also allowed to generate and manage the E-way Bill Numbers on behalf of the supplying or receiving parties.
 
Any person who is registered with the E-way Bill System can generate the E-way Bill Numbers. Supplier, Receivers, and Transporters who are registered with GST system and possess a GST identification number (GSTIN) can register themselves with E-way Bill System using their GSTIN.
 
Section 2(84) of the CGST Act terms the person who is not registered under the Act as an unregistered person (URP).
 
As an example, persons having an annual turnover less than Rs 20 lakhs are not liable to obtain a GST registration and hence will get classified as an unregistered person. Such unregistered persons as part of their usual business process, however, may need to transport goods.
 
Let us look at some key rules applicable to the unregistered persons for E-way Bills.

1.  Is an unregistered person required to generate E-way Bill?

Where an unregistered party is involved in a transaction, the onus of generation of the E-way Bill is shifted to the registered party.
Where none of the parties to the transaction are registered, then either of the parties needs to register with GSTN or the transporter needs to generate the E-way Bill.
 

2.  What are details of an unregistered dealer required to be entered at the time of generation of E-way Bill?

In the GSTIN field, 'URP' needs to be mentioned where the counterparty (either the supplier or receiver) is an unregistered person. 
Name is not a mandatory field, but it is recommended to mention the trade or legal name of the unregistered party. Address, state and PIN code are required to be updated as it is.
 

3.  If the transporter is an unregistered person, can he/ she still generate an E-way Bill on behalf of suppliers and receivers?

E-way Bill Numbers can be generated by persons who are registered with the E-way Bill system.
If the transporter is an unregistered person, then he/she will need to enrol with the E-way Bill system in order to be eligible to generate E-way Bill Numbers.
 
Upon enrolment with E-way Bill System, the transporter is given a unique 15-digit identification number, referred as Transporter ID. This Transporter ID needs to be mentioned while generating E-way Bill Number.
 

4.  If the transporter, who is an unregistered person, does not enrol with E-way Bill System, can he/she update the vehicle details in E-way Bills which are generated by the suppliers or the recipients?

Vehicle details can be updated by the generator of E-way Bill or the transporter if the Transporter ID is mentioned. Transporter ID can either be GSTIN if the transporter is a registered person or the unique ID given by E-way Bill system upon enrolment.
 
If the unregistered person does not get enroled with E-way Bill system as a transporter, then vehicle details cannot be updated by them. Hence, in order to keep the transport transaction and E-way Bill process hassle free, a transporter should ideally get registered.
 
IRIS is an established GST Suvidha Provider (GSP) and was one of the first GSPs to complete the integration with NIC's E-way Bill System. IRIS has been in the financial compliance space for over 2 decades and has worked with regulators and filing entities alike. We have supported MCA filings for over 700 entities including companies of groups such as Tata, Reliance, TVS, Godrej, L&T etc.  Our E-way Bill solution, branded as IRIS Topaz, is an end-to-end solution for entire E-way Bill cycle. IRIS Topaz can be accessed through the web, desktop utility, and APIs.  
 
You can avail our 15-day free trial offer of the full version of IRIS Topaz. You can enrol for a free webinar here. For further details please write to support@irisgst.com or visit our site https://irisgst.com

About Anushree Joshi

Anushree Joshi, a CA and CMA, is associated with IRIS as Business Analyst for over 7 years. She is actively involved in the IRIS GST product development and client interactions and issue handling . Before GST she was handling US compliance analyzing US financial statements and reviewing XBRL filings for US and India market. In her leisure time, she enjoys reading and put up her feet on the classical dance form of Kathak.

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<a href="http://mygstzone.com/">A.K.Pandey</a> 5 months, 2 weeks ago

Hi,
Thanks for sharing this blog with us, I read your article, your blog contains very important information for us, I appreciate your work and effort. You have GST Expert level of knowledge.

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Anushree 5 months, 2 weeks ago

Hi, Thank-you so much for the appreciation!

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Anushree 5 months, 2 weeks ago

Glad you liked the blog. Thank-you for the words of appreciation!!

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HIMANARAYANA 4 months, 3 weeks ago

my export firm(where i am working) sends pp bags to suppliers to get their cargo in our bags back to us. pls enlighten me the procedure involved in here.

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himanarayana 4 months, 3 weeks ago

thanks for your knowledge sharing. my firm (where i am working) sends pp bags to suppliers to get their cargo packed in them and the same bags will beback to us. enlighten me the eway bill procedure involved in here in such scenarios.

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Anushree 4 months, 3 weeks ago

Thank-you for reading through the blogs. We will be shortly publishing a blog on exports as well. Kindly stay tuned to our blogs.

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generate eway bill 4 months, 1 week ago

nice post i love this post

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generate eway bill 4 months, 1 week ago

thanks for sharing

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generate eway bill 4 months, 1 week ago

nice post thanks for sharing this

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Shree Balaji 2 months ago

I am an unregistered dealer. My turn over is less than 20 lacs per annum. I make hand made products. I want to sell my products at a consumer(general public) exhibition. My question is: 1) Do I need to raise invoice during the time of sale 2) To transport my products back and fourth do i need eway bill.
Thanks

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Anushree Joshi 2 months ago

Hello Sir,
Thank You for going through my blog. As for your query.
1) Do I need to raise invoice during the time of sale
--> Since you are an Unregistered Dealer as defined under GST Act, and your turn-over not being crossing the threshold, you may not raise an invoice. But, as per standard accounting principles, you will require to keep the accounting for sales made in bill book and further accounting of the same. This will also be required for determining your turn-over while filing your Income-tax return.

2) To transport my products back and fourth do i need eway bill.
--> As per the E-way Bill rules, only a registered person who is making the movement of goods of which the value exceeds Rs.50,000/- and such movement is being carried in motorized vehicle is liable to generate E-way bill. However, as a matter of sound business practices and common business principles, every movement of goods for business purpose should be covered by an E-way bill because, in an event of detention of the vehicle or stoppage for routine checking of goods by Authorities, proving the Authorities that turn-over is less than Rs.20Lakhs and that you are unregistered dealer will be not easy and feasible and will be quite cumbersome.

Also, if this movement is an inter-state movement of goods, then whether or not you are registered person under GST provisions, you need to generate E-way bill.

You can enroll yourself on https://ewaybillgst.gov.in/ewb.html as a 'CITIZEN' and can generate such E-way bills.

Hope this helps in clearing your query.

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