Since the date of enforcement of e-way bill has been announced, the buzz regarding its implementation has started. More or less the concept of e-way bill is clear, it is supposed to monitor the movement of goods & to ensure that the GST law has been complied with. Even the e-way portal www.ewaybill.nic.in is easy to understand. But the real practical issues which the business unit is going to face, still remains unanswered.
First and foremost the portal does not clarify how to generate e-way bill in case where some proportion of movement of goods is done by the business unit itself and the other proportion is done by the transport agency. For instance the company situated in Gurugram would first send goods to transport in delhi and then the goods move to the final destination. In such a scenario either the business unit has to transfer goods to transport agency by way of delivery challan and further such agency generates a new e-way bill or the business unit generate the e-way bill for its final destination and once goods reach to transporter in Delhi, the transport agency updates the vehicle number. In either of the case, supplier remains dependent on the transport agency. In the second case the issues regarding the validity of e-way bill is going to arise.
Second issue we find in e-way bill is in the case of Bill-to-Ship-to transactions, where the bill is raised against the third party and the goods are being transported to someone else. For example, M/s ABC ltd. of Delhi orders M/s XYZ Ltd. of West Bengal to supply goods directly to its customer M/s PQR Ltd. in Assam. In such a scenario there are two school of thoughts are prevailing, one as suggested in FAQ issued by government, two eway bills will be required, one from West Bengal to Delhi and second one from Delhi to Assam. This understanding is certainly going to raise never ending problems. First the goods are actually moving from West Bengal to Assam, for which no e-way bill is generated. Another major problem which it is going to raise is the bogus billing and unaccounted goods having the same HSN codes can be easily moved from West Bengal to Delhi or from Delhi to Assam. Another school of thought states that only one eway bill should be generated from West Bengal to Assam. In such a case there shall be ease of compliance and the e-way will depict the real movement of goods and not what is shown in the documents. If the government really wish to resolve this issue it should come up with both Billed to and Shipped to details at its e-way bill portal. This shall reduce all the anomalies regarding such transactions.