Compliance with ‘Bill to’ and ‘Ship to’ in Eway Bill

A standard practice in the industry is for goods to be sold to one person but delivered to a different location. The delivery address would differ from the buyer's registered office address in that case. This type of translation falls under the "bill-to-ship-to" of GST.

This difference in 'Bill To' and 'Ship To' addresses must be addressed carefully when issuing an invoice and generating an E-way bill.

Delivery at a different place

There are certain circumstances under which the goods being transferred are sent to a location other than the location of the purchaser (registered address). Below are some examples of peculiar circumstances where a buyer may ask for delivery at a different location or to a third party:

• Buyer requires delivery at one of his warehouses, which is at a location other than his registered office.
• Buyer (trading business) requires delivery of goods directly to one of his customer's (third party) locations.
• The buyer requires delivery of goods to a specially designed storage facility (e.g., cold storage, customs warehouse).
• Buyer requires delivery of goods to an institutional customer to whom he has already sold the goods further who is at a different location.
• Buyer's customer is a retail chain that requires the delivery of goods to various outlets.

Under all the above-stated circumstances, the 'Bill to' and 'Ship to' addresses as in the GST invoice shall differ. The customer buying the goods has his billing address at his registered office address. In contrast, the goods are shipped to a different address. 

The addresses are required when generating the Eway Bill for the transfer of goods. The person should mention the buyer's GSTIN and the delivery location. The delivery location shall be the actual delivery location where the goods are to be delivered, not the billing location (in case the delivery location differs from the billing address).

Bill To and Ship To under Eway Bill

Scenario 1

In this scenario, although the 'Bill to' and 'Ship to' addresses are different, the delivery is necessary to the same person, i.e., with the same GSTIN. This can happen when a buyer requests delivery of goods to one of his warehouses or storage facilities. It is nothing but a case of simply moving the goods to an additional place of business instead of the primary place of business by the buyer directly from the supplier.

Example: Ashish is a shoe dealer with a registered office in Mumbai. Because of the size of his operations, he has multiple warehousing facilities in different parts of Maharashtra to facilitate effective supply-chain management. He bought 2,000 pairs of shoes from Black Soles Pvt. Ltd. in Nasik, Maharashtra for further sale. On purchase, he requested the supplier ship the consignment to one of his warehouses in Pune. 

In this case, although the goods are 'Billed to' Ashish's Mumbai office address, they are 'Shipped to' his warehouse in Pune. The GST invoice shall clearly show the two addresses as 'Bill to' and 'Ship to'. Also, this will be an intra-state transaction and CGST and SGST will be charged.

The transporter shall carry the Eway Bill during transit.

Scenario 2

In this scenario, the 'Bill to' and 'Ship to' addresses are different, and delivery is made to a different person, i.e. with a different GSTIN. This can happen when the goods are transferred directly to the buyer's customer (third party) from the supplier's location.

Continuing with the above example,

Case 1: Instead of requesting that the goods be transferred to his warehouses, Ashish requests that Black Soles Pvt. Ltd. sent the shoes to Vijay, one of his wholesale customers in Pune, Maharashtra. 

• In this case, two invoices will be issued as GSTIN differs for all the parties involved i.e 
  1. Invoice for transaction between Black Shoes Pvt. Ltd to Ashish and
  2. Invoice for transaction between Ashish to Vijay
• This will be an intra-state transaction and CGST and SGST will be charged in both the invoices
•  The Eway Bill requirements will not differ from the case above because physical movement is happening only once. Hence, only one eway bill has to be generated, either Black Soles Pvt. Ltd. or Ashok in Mumbai to transfer shoes to Vijay in Pune.

Case 2: In the above example, if Ashish had requested to send the shoes to one of his wholesale customers, Vijay, in Vijayawada, Andhra Pradesh, then while raising the invoice he would have charged IGST as place of consumption i.e. Andhra Pradesh is different from the place of supply i,e, Mumbai, Maharashtra.

Note: Only one eway bill is required to be generated because the physical movement is happening only once here also.

Responsibility for generating the Eway Bill

Under the "Bill To Ship To" model of supply, there are three persons involved in a transaction:

• 'A' is the person who has ordered 'B' to send goods directly to 'C'
• 'B' is the person who is sending goods directly to 'C' on behalf of 'A'
• 'C' is the recipient of goods

Here, two supplies are involved, and two tax invoices are required to be issued:   

• Invoice -1, which would be issued by 'B' to 'A'   
• Invoice -2, which would be issued by 'A' to ‘C’

Case -1: Where e-Way Bill is generated by 'B'

The following fields shall be filled in Part A of GST FORM EWB-01:

Case -2: Where e-Way Bill is generated by 'A'

The following fields shall be filled in Part A of GST FORM EWB-01:

To conclude, it is fair to mention that only one Eway Bill must be generated for the transfer of goods to a location different from that buyer within under the “Bill to Ship to” model.