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Compliance with Eway bill rules for Transshipment of goods

Updated on:  

08 min read

E-way bills system supports various practical issues faced by users in delivering goods. Particularly, several complexities may be involved in the movement of goods from the source to the destination, supplier or transporter faces hurdles en route like the breakdown of a vehicle or otherwise may have to deviate routes or change the transport mode.

Latest Updates of 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.

17th March 2021
1. The e-way bills portal has released an update stating that e-way bills cannot be generated with only SAC codes (99) for services. There should be a minimum of one HSN code belonging to goods mentioned mandatorily.
2. Vehicle type ODC is provisioned for transport mode ‘Ship’.
3. Transporters are provided with a report of e-way bills based on the assigned date.

22nd December 2020
1. The CBIC increased the distance per day in case of goods transported through vehicles, other than the over-dimensional cargo, for determining the validity, as follows:
(a) It is one day – For a distance of up to 200 km as against earlier 100 km
(b) An additional day is taken- For every additional 200 km or part thereof, as against previously notified additional 100 km or part thereof
2. Regarding blocking of the e-way bill where a taxpayer fails to file GSTR-3B, the provision has been amended to replace two or more months with two or more tax periods. The same has been changed to include the quarterly return filers.

16th November 2020
1. According to Rule 138E (a) and (b) of the CGST Rules, 2017, the e-way bill generation facility of a taxpayer will be restricted, if the taxpayer fails to file their Form GSTR-3B returns or statement in Form GST CMP-08, for tax periods of two or more.
2. On 1st December 2020, the system will check the status of returns filed in Form GSTR-3B or the statements filed in Form GST CMP-08, for the class of taxpayers to whom it applies, and restrict the generation of e-way bill in case of:
(a) Non-filing of two or more returns in Form GSTR-3B for the months up to October 2020; and
(b) Non-filing of two or more statements in Form GST CMP-08 for the quarters up to July to September 2020
3. From 1st December 2020 onwards, blocking of e-way bill generation facilities would be made applicable to all taxpayers, irrespective of their Aggregate Annual Turnover (AATO), according to the terms of Rule 138E (a) and (b) of the CGST Rules, 2017.
4. The blocking will take place periodically from 1st December 2020 onwards.
5. To continue generating e-way bill on the e-way bill portal, taxpayers are advised to file their pending GSTR-3B returns/GST CMP-08 statements immediately.

What is Transshipment

Transshipment” means change in the mode of transport/conveyance or change of vehicle during the transit of goods.  This could happen in various circumstances

  1. Change in Conveyance – Rail to Road
  2.  Shifting of goods from a large vehicle to a smaller vehicle
  3. Breakdown of the original vehicle

Suppose ABC Transporters are transporting say 500 kgs of certain material to Delhi out of which 5 Kgs is required to be delivered in the narrow lanes of Chandni Chowk in Delhi.  ABC Transporters are transporting these goods by a truck and the goods reach Delhi. The goods are unloaded at the transporters warehouse. Now the transporter is expected to deliver 5kgs of these goods at Chandni Chowk where entry of a truck would be rather difficult to transport small quantity of goods.  

The transporter can shift the goods to a small tempo for delivery of goods to the desired location. The movement of goods from supplier to recipient has not been terminated in this case but the mode of transport has been changed. This is referred to as Transshipment.

E-way bill requirements in case of Transshipment

Eway Bill is required for movement of goods. One movement requires one eway bill. There is no requirement to generate multiple eway bills for change in a mode of conveyance In case the eway bill is generated by mentioning a vehicle number and subsequently, the goods are transshipped to another vehicle or there is a change in the mode of conveyance, such Change in the vehicle/mode of transport can be updated on the eway bill on the common portal or through SMS

Update e-way bill online for transshipment

Change in the vehicle/mode of transport can be updated on the eway bill portal by following the below steps

Step 1

1

Login >> Main menu >> E-way Bill >> Update Part B/Vehicle

Please note that the vehicle numbers can be updated in bulk as well.  This feature can be useful for changing the Mode of transport or change the vehicle number in a case where multiple shipments are being consolidated and are being transported through a single vehicle which breakdowns during the journey or change in the mode of transport say from Road to Rail etc.   Additionally, in case the transporters regularly transport the goods to a particular point and then consolidate the goods which are to be delivered to a particular location, he can use this feature to easily change the vehicle number and update the eway bill will the new vehicle which will be carrying the goods.

Step 2

2

>Enter the Eway bill no Please note that the eway bill can also be checked based on the date of generation of eway bill in case the eway bill number is not available at the time of updating the vehicle number for transshipment of goods to another vehicle

Step 3

3

> Update the details

Example: 1 ABC Transporters are transporting goods which were sold by XYZ Limited, Mumbai to PQR Limited, Delhi.  The goods are getting transported by Road. The eway bill in this case was updated by XYZ Limited, Mumbai by providing the Transporter ID of ABC Transporters in Part B.  ABC Transporters generated the eway bill by entering the vehicle number which would be used to transport the goods.

In the course of transport of goods, the original transport vehicle breaks down and ABC Transporters is required to accommodate these goods on another truck.  In this case, ABC Transporters can use the option of Update Part B and provide the details of change in vehicle before the movement of goods.

Example: 2 In case ABC Transporters are transporting goods from Kolhapur, Maharashtra to Mumbai by road and then from Mumbai to Kolkata by Train and from Kolkata Railway Station to the recipient location by road then the transporter can follow the below procedure

  1. Generate eway bill at the time of movement of goods by road using the vehicle number for transport till Mumbai
  2. Update the Railway Receipt No. and date at the time of change in the mode of transport at Mumbai
3

3. Update the new Vehicle Number at the time of change in the mode of transport at Kolkata Railway Station

Not Required- Eway bill updation for transhipment of goods

  • Transport of goods up to the place of export and change in conveyance therefrom
  • Transport of goods up to the place of the transporter up to 50 kms from the location of the supplier
  • Change in mode of transport to a non-motorized conveyance

Important highlights to note on e-way bill compliance here

  1. In case of transshipment of goods, only Part B of the eway bill needs to be updated
  2. Part B can be updated by the supplier who has updated Part A of the eway
  3. If the transporter ID is mentioned at the time of generation of eway bill then the transporter can also update Part B to provide for the details of the change of vehicle
  4. Part B of the eway bill needs to be updated before the change in vehicle
  5. Part B can be updated only within the validity period of the eway bill
  6. There is no restriction on the number of times the eway bill can be updated due to transshipment of goods.  In fact, the vehicle updation history is available for each of the eway bill at the time of updating the vehicle details
  7. In case the supplier of goods wants to change the transporter or re-assign the eway bill, he can do the same by using the option “Change/ Re-assign another transporter”.  However, once the original transporter re-assigns another transporter in his place, the supplier cannot update Part B of the eway bill.

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