Compliance For eWay Bill by Transporter and Other Important Rules

Transporters must be aware of the e-way bill rules prescribed by the GST law. It is because they are also made liable for non-compliance on their part wherever an e-way bill needs to be generated but is failed to be created by the supplier or the recipient, as applicable.

Latest updates on e-way bills

29th August 2021
From 1st May 2021 to 18th August 2021, the taxpayers will not face blocking of e-way bills for non-filing of GSTR-1 or GSTR-3B (two months or more for monthly filer and one quarter or more for QRMP taxpayers) for March 2021 to May 2021.

4th August 2021
Blocking of e-way bills due to non-filing of GSTR-3B resumes from 15th August 2021.

1st June 2021
1. The e-way bill portal, in its release notes, has clarified that a suspended GSTIN cannot generate an e-way bill. However, a suspended GSTIN as a recipient or as a transporter can get a generated e-way bill.
2. the mode of transport ‘Ship’ has now been updated to ‘Ship/Road cum Ship’ so that the user can enter a vehicle number where goods are initially moved by road and a bill of lading number and date for movement by ship. This will help in availing the ODC benefits for movement using ships and facilitate the updating of vehicle details as and when moved on road.

18th May 2021
The CBIC in Notification 15/2021-Central Tax has notified that the blocking of GSTINs for e-Way Bill generation is now considered only for the defaulting supplier’s GSTIN and not for the defaulting recipient or the transporter’s GSTIN.

What is Transporter ID and how to enrol for it?

Transporter ID or TRANSIN is a 15-digit unique identification number allotted to an unregistered transporter enabling generation of e-Way Bills. It is generated based on the State code, PAN and check sum digit.

All Transporters are required to generate e- way bill if: 

(a) Value of consignment/value of goods of a single supplier exceeds Rs.50,000.

OR 

(b) Value of all the goods in a vehicle through which goods are transported cumulatively exceeds Rs.50,000.

Even the unregistered transporters under GST have to note that e-way bills are required to be generated by them under the above circumstances. Since unregistered transporters will not have a GSTIN, the concept of transporter ID has been introduced.   

Where and when to use the Transporter ID or TRANSIN? 

Unregistered transporters have to mention this ID on every e-way bill in the place of GSTIN. Transporters provide this number to the suppliers/consignor to mention it on the e-way bills generated by them which in turn enables the transporter to update the vehicle number later for movements of goods.   

Procedure to be followed by Unregistered transporters to get the transporter ID or TRANSIN? 

Every unregistered transporter will be issued a transporter ID on enrolling themselves on the EWB portal. By doing enrolment on e-way bill portal, the following are the outcome: 

i) The transporter gets a unique transporter ID or TRANSIN.

ii) A unique username to operate on the e-way bill portal.

Here is the step-by-step process for enrolment on the e-Way Bill portal by GST unregistered transporters: 

Step-1: Visit the e-way bill portal.  

Step-2: Click on ‘ Enrolment for transporters ’ under the Registration tab available on the Home page.

Step-3: Enter the details in the Application at points 1-9 and Click ‘Save’. 

Let’s go through the entire ‘Application u/s 35(2)’ in GST ENR-01 for each of the 9 points: 

Note that the fields marked (*) in red are mandatory.1. Select Your State*. 

2. Enter certain details:

a) Enter Name as per PAN*. 

b) Enter Trade name, if any.

c)  Enter your PAN* (Note that once you enter PAN and click on Validate, the system validates for any error or mismatch, and rectifies the same before proceeding). 

3. Type of enrolment*:

Note: The system does not allow you to proceed here without entering the details at point 1 and 2. Select the relevant type- warehouse/godown/cold storage/transport service.

4. Constitution of business*: Select the relevant business form from the drop down- foreign company/partnership firm/ proprietorship/ private limited company/ public limited company/unlimited company/ others (If HUF, AOP, BOI and so on)

5. Principal place of business

a) Type in the complete address entering all the red marked mandatory fields.* 

b) Contact information: Type the e-mail address, landline number and fax number (if any) 

Note: The e-mail address mentioned here shall be used for authentication. 

c) Nature of premises mentioned at a)- Select whether the address at a) is a building that is owned /leased /rented/ consent/ shared/ any other case.

6. Aadhaar details and verification for authentication of the application* : Tick mark on the left-hand side box to give your consent to the e-Way Bill System/GSTN to fetch Aadhaar details of the authorised personnel of the organisation from UIDAI for authentication here. 

In the fields that follow, mention the following with respect to the authorised personnel of the company/ the proprietor/ the partner of the firm: The Aadhaar number, name of the personnel and mobile number as per Aadhaar. Once entered, Click on the ‘Verify detail & Send OTP’ button. 

An OTP is sent to the Mobile number registered with Aadhaar of the above-mentioned personnel. Enter it and click on ‘Verify OTP’ A message that Your Aadhaar was successfully verified appears. 

7. Upload: Click on ‘Browse’ and select valid documents from your system (one for address proof and one for ID proof) in PDF and click on ‘Upload’. System pops an error message if not uploaded correctly, then makes the change to the file accordingly and uploads once more. If correctly uploaded, then the file name appears on the right-hand side of each field.

8. Create Login details* : Set a new unique username/ user ID and password. Check if the username you wish to set is already being used or not by clicking on ‘Check’. 

9. Verification* : Tick mark against the declaration confirming the correctness of the information you give and Click ‘Save’. 

Outcome: System generates a 15-digit transporter ID or TRANSIN and displays the same. Note this number and inform clients.

What happens if the transporter changes the mode of conveyance during transit?

If a transporter is transferring goods from one conveyance to another during the course of the transit, then they must update the details of the new conveyance in the e-way bill already generated on the e-way bill portal in the form EWB-01, before such transfer takes place.

The caveat here is that if the goods are being transported to a consignee for a distance of fifty kilometres or less, within the same State or Union territory as the place of business of the transporter, the details of conveyance need not be updated in the e-way bill.

What is the rule to be followed when transferring multiple consignments in a single conveyance?

Where a transporter is moving more than one consignment in one conveyance, he must indicate the serial number of e-way bills for each consignment electronically on the e-way bill portal. A consolidated e-way bill in form EWB-02 must be generated before the movement of goods.

How to deal with the situation of transshipment of Goods?

“Transshipment” means the change in the mode of transport/conveyance or change of vehicles during the transit of goods.  Portal provides an option in such a case to the transporter/generator of the e-way bill to update the vehicle number on e-way Bill of the vehicle in which he is transporting that consignment. 

The seller or the transporter mentioned in Part A of the e-way bill can only update the vehicle number and this can be done ‘n’ number of times. Eway bill portal has also provided an option to change/ re-assign another transporter to an Eway bill. Once the originally assigned transporter re-assigns another transporter in his place, the seller cannot exercise this option any longer.  

What are the documents to be carried by the person-in-charge of conveyance?

The person-in-charge of a conveyance must carry:

• The invoice or bill of supply or delivery challan and
• A copy of the e-way bill or the e-way bill number, either physically or mapped to a RFID (Radio Frequency Identification Device). RFID is embedded onto the conveyance (mode of transport). Details of these will be notified by the commissioner. However, the commissioner may notify person-in-charge to carry the following documents instead of the e-way bill –
  • Tax invoice or bill or supply of bill of entry or
  • A delivery challan, where goods are transported other than by way of ‘supply’

A registered person can submit a tax invoice in form INV-1 on the e-way bill portal. After which he will get an Invoice Reference Number (IRN). IRN is valid for 30 days from the date of uploading. It can be given for verification by an officer instead of the tax invoice.

Note that where a registered person uploads the invoice, information in Part A of Form GST INS-1 is auto populated from GST INV-1. The commissioner may notify a class of transporters to get a unique RFID. This RFID will be embedded on to the conveyance (mode of transport) and mapped to the e-way bill before the movement of goods. 

What is the process for stopping vehicles and verification of documents in transit? 

Any mode of transport can be stopped for inter-state and intra-state movements. The Commissioner, or an officer empowered by him, may authorise an officer to stop a consignment to verify e-way bill. RFID readers will be installed at places where verification of movement of goods is required. 

Verification will be done through RFID readers where e-way bills are mapped with RFID. Physical verification of conveyances may also be done. In case there is ‘specific information’ of tax evasion, physical verification of a conveyance can also be done by an authorised officer.

What is the process of inspection and verification of goods?

A summary of every inspection of goods in transit will be recorded online by the officer in Part A of GST EWB-03 within 24 hours of inspection. The final report will be submitted in Part B of GST EWB-03 within 3 days of inspection. Goods will be inspected only once during a journey. However, if any ‘specific information’ of tax evasion is available even after an inspection is already done, the vehicle can be stopped again. If a vehicle is intercepted or stopped or detained for more than 30 minutes the transporter can upload this information in Form GST EWB-04 on the common portal.

FAQs regarding e-way bill compliance by transporters

What to do if I get errors such as ‘PAN details or Aadhaar details are not validated’?

It indicates that the PAN number is not validated on the income tax portal. On the other hand, the Aadhaar number, name or/and the mobile number entered are not getting validated by the Aadhaar system. Hence, you must enter the correct details.

How will the transporter know that the e-way bill is assigned to him?

The transporter will know in one of the following ways:

(i) Upon logging in to the EWB portal, the transporter can navigate to the ‘reports’ section and choose the ‘EWB assigned to me for trans’ and checkout the list. Alternatively, the transporter’s assignment of e-way bills can also be found on his dashboard.

(ii) The transporter can navigate to ‘Update Vehicle No’ and choose the ‘Generator GSTIN’ option and enter the taxpayer’s GSTIN who has assigned the EWB to him.

What happens when an e-way bill is generated but the goods are not transported?

Where an e-way bill is generated but goods are not transported or are not transported as per the e-way bill, the e-way bill may be cancelled within 24 hours. This can be done directly or via a facilitation centre which will be notified by the Commissioner.

Note: An e-way bill cannot be cancelled if it has been verified in transit where the mode of conveyance has changed.

Who can accept or reject an e-way bill?

A recipient can accept or reject an e-way bill. An e-way bill will be assumed to be accepted if there’s no communication within 72 hours of the e-way bill being made available to the recipient via the common portal.

For further reading and understanding on e-way bills:

• How to generate e-way bills on the portal?
• How to use SMS facility to generate/modify/cancel e-way bills?
• How to generate consolidated e-way bills on the e-way bill portal?