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

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

by Anushree | April 11, 2018

 

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 Eway bill rules require for all movement of goods meeting the specified criteria, a unique number to be obtained from the Government’s system and this unique number, referred as Eway 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 Eway Bill Number. Read our article ‘6 Things You Need to Know about e-Way Bill’ to know more about eWay bill. 
 
Typically, the person initiating the movement of goods is responsible for generating the Eway Bill Number. However, the transporters are also allowed to generate and manage the Eway Bill Numbers on behalf of the supplying or receiving parties.
 
Any person who is registered with the Eway Bill System can generate the Eway Bill Numbers. Supplier, Receivers, and Transporters who are registered with GST system and possess a GST identification number (GSTIN) can register themselves with Eway 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 ?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 may need to transport goods.
 
Let us look at some key rules applicable to the unregistered persons for Eway Bills.
1.  Is an unregistered person required to generate Eway Bill?
Where an unregistered party is involved in a transaction, the onus of generation of the EWB 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 Eway Bill
 
2.  What are details of an unregistered dealer required to be entered at the time of generation of EWB?
In the GSTIN field, ‘URP’ needs to be mentioned where the counterparty (either the supplier or receiver) is an unregistered person. 
Name, though is not a mandatory field, 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 Eway Bill on behalf of suppliers and receivers?
Eway Bill Numbers can be generated by persons who are registered with the Eway Bill system.
If the transporter is an unregistered person, then he/she will need to enroll with the Eway Bill system in order to be eligible to generate Eway Bill Numbers.
 
Upon enrollment with Eway 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 Eway Bill Number.
 
4.  If the transporter, who is an unregistered person, does not enroll with Eway Bill System, can he/she update the vehicle details in Eway Bills which are generated by the suppliers or the recipients?
Vehicle details can be updated by the generator of Eway 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 Eway Bill system upon enrollment.
 
If the unregistered person does not get enrolled with Eway Bill system as a transporter, then vehicle details cannot be updated by them. Hence, in order to keep the transport transaction 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 Eway 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 Eway Bill solution, branded as IRIS Topaz, is an end-to-end solution for entire Eway 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 enroll for a free webinar here. For further details please write to support@irisgst.com or visit our site www.irisgst.com
 
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