Issues regarding “Bill To Ship To” for e-Way Bill under CGST Rules, 2017

[CA Nihalchand Jain]

Let us understand the working of Bill To Ship To Model and E-Way Bill under GST Rules. We try to understand the same with the help of an example. In a typical bill to ship to model, there are ideally 3 people involved. Let us name them as:
1. Mr. A – The recipient of the goods [As per Section 10(1)(b) of the IGST Act, 2017]
2. Mr. B – The supplier of the goods
3. Mr. C – The actual recipient of the goods

Hence, to avoid any possible confusion, the above scenario can be summarized in one line – Mr. A has placed an order on Mr. B to deliver the goods at the location of Mr. C. Hence, Mr. C will be actually receiving the physical possession of the goods on direction of Mr. A.

Continuing our discussion, As per Section 10(1)(b), there are ideally TWO supplies
1. From Mr. B to Mr. A (Supply 1 / Tax Invoice 1)
2. From Mr. A to Mr. C (Supply 2 / Tax Invoice 2)
taking place in the above scenario and hence, ideally, there would be two Tax invoices / Bill of supplies issued for the said supply.
BUT BUT BUT, there is ONLY ONE movement of goods happening in the entire model from the location of Mr. B to the location of Mr. C.

How to tackle the same in the E-Way bill is clarified in the said Press Release as queries were raised as to who would generate the E-Way Bill for the movement of goods which is taking place from location of “Mr. B” to location of “Mr. C” on behalf of “Mr. A”. The same in question – answer form is presented below:-
Question 1 – How many E-Way bill is required to be generated?
Answer – ONLY ONE E-Way bill is required to be generated.

Question 2 – Who will generate E-Way bill?
Answer – As per Rule 138, either the Supplier or the Recipient can generate E-Way bill. Therefore, in our case, either Mr. B (Supplier) or Mr. A (Recipient) can generate the said E-Way bill.

Question 3 – What are the details to be submitted if Mr. B generates E-Way bill?
Answer – In case, Mr. B (the supplier) generates, E-Way Bill, he needs to ensure correct details of the 5 things mentioned below:
1. Bill From: In this field, details of “Mr. B” are supposed to be filled.
2. Dispatch From: This is the place from where goods are actually dispatched. It may be the principal or additional place of business of “Mr. B”
3. Bill To: In this field details of “Mr. A” are supposed to be filled.
4. Ship to: In this field address of “Mr. C” is supposed to be filled.
5. Invoice Details: Details of “Invoice Number 1 i.e. From Mr. B to Mr. A” are supposed to be filled

Question 4 – What are the details to be submitted if Mr. A generates E-Way bill?
Answer – In case, Mr. A [The recipient as per Sec 10(1)(b) of the IGST Act, 2017] generates, E-Way Bill, he needs to ensure correct details of the 5 things mentioned below:
1. Bill From: In this field details of “Mr. A” are supposed to be filled.
2. Dispatch From: This is the place from where goods are actually dispatched. It may be the principal or additional place of business of “Mr. B”.
3. Bill To: In this field details of “Mr. C” are supposed to be filled.
4. Ship to: In this field address of “Mr. C” is supposed to be filled.
5. Invoice Details: Details of “Invoice Number 2 i.e From Mr. A to Mr. C” are supposed to be filled.

YouTube Link for the Video – https://www.youtube.com/watch?v=RHQcVn9flzM

• This topic was modified 6 years, 7 months ago by CA Nihalchand Jain.

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