E-way Bill - Storing of Goods with Transporter

Due to the weak financial condition, the weavers and the artisans in the textile sector generally store their goods in the warehouse of the transporter. The transporters who are providing such warehousing facility will have to mandatorily get themselves registered under Goods and Service Tax (GST) and further the transporters needs to maintain detailed records of goods received for storage and further transportation of goods till the consignee / recipient’s premises. Due to the difficulty faced by the transporter, the textile industry had made representation and requested to treat the godowns of the transporter as ‘transit godowns’. In this article, we look at the provisions relating

e-way bill while storing goods with Transporter.

Clarification on The Above Issue

Vide circular no. 61/35/2018 – GST dated 4th September 2018 and by exercising, powers conferred under section 168 (1) of the Central Goods and Service Tax Act, 2017, the board has provided below mentioned clarification:

E-way Bill Requirement

As per provisions contained in rule 138 of the Central Goods and Service Tax Rules, 2017, e-way bill generation is mandatory for any movement of goods. In view of the said rule, any the movement of goods, including when goods are stored in the godown of the transporter before delivery, should always be accompanied by the valid e-way bill.

Place of Business

The definition of ‘place of business’ is contained under section 2 (85) of the Central

Goods and Service Tax Act, 2017 and, as clarified under the above referred circular, ‘place of business’ would include ‘a place from where the business is ordinarily carried out, and includes a warehouse, a godown or any other place where a taxable person stores his goods, supplies or receives goods or services or both”. It is further clarified that an additional place of business is the place of business from where the taxpayer carries out business related activities within the State, in addition to the principal place of business.

Situation Where Consignee / Recipient Uses Godown Of The Transporter For Warehouse

When the consignee / recipient of goods uses godown of the transporter for storage purpose, in such case, the consignee / recipient taxpayer is required to declare the transporter’s godown as an additional place of business. The mere declaration by the consignee / recipient taxpayer to this effect with the concurrence of the transporter in the said declaration will serve the purpose. Once the transporter’s godown has been declared as the additional place of business by the consignee / recipient taxpayer, the transportation under the e-way bill shall be deemed to have been concluded once the goods have reached the transporter’s godown. Resulting thereby that no e-way bill validity needs to be extended. However, e-way bill provisions shall be applicable in case of movement of goods from the transporter’s godown to any other place of the consignee / recipient taxpayer.

Maintenance of Accounts And Records

It has been clarified in the above referred circular that as per provisions of section 35 of the Central Goods and Service Tax Act, 2017, the transporter is required to maintain required accounts and records as a ‘warehouse keeper’. Further, the consignee / recipient taxpayer is also required to maintain required accounts and records as per rule 56 and 57 of the Central Goods and Service Tax Rules, 2017. It must be noted that books of accounts for goods stored at the transporter’s godown can be maintained by the consignee / recipient at his principal place of business [as per rule 56 (7)]. Know more about

GST accounts maintenance.

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Frequently Asked Questions

Common questions about E Way Bill for Storing Goods with Transporter under GST.

As per the article, transporters who provide warehousing facilities for storing goods of weavers and artisans in the textile sector need to mandatorily register under Goods and Services Tax (GST). This is because they are providing a taxable service of storing goods, which requires them to comply with GST regulations.

According to the rules mentioned in the article, an e-way bill is mandatory for any movement of goods, including when goods are stored in the transporter's godown before delivery to the consignee or recipient. The e-way bill ensures proper tracking and documentation of the goods' movement and storage.

The article clarifies that when the consignee or recipient taxpayer uses the transporter's godown for storage purposes, they are required to declare the transporter's godown as an "additional place of business." This declaration, with the transporter's concurrence, enables the consignee to consider the transportation under the e-way bill as concluded once the goods reach the transporter's godown.

As per the clarification provided in the article, once the transporter's godown has been declared as an additional place of business by the consignee or recipient taxpayer, there is no need to extend the validity of the e-way bill. The transportation under the e-way bill is deemed to have concluded when the goods reach the transporter's godown.

The article states that transporters are required to maintain accounts and records as warehouse keepers under Section 35 of the CGST Act. Additionally, the consignee or recipient taxpayer must maintain accounts and records as per Rules 56 and 57 of the CGST Rules, though the books of accounts for goods stored at the transporter's godown can be maintained at their principal place of business.

Yes, the article clearly mentions that as per Rule 56(7) of the CGST Rules, the consignee or recipient taxpayer can maintain books of accounts for goods stored at the transporter's godown at their principal place of business.

The circular no. 61/35/2018-GST, issued by the GST Board, provides clarifications on the provisions related to e-way bills and the treatment of transporters' godowns as "additional places of business" for consignees or recipients. The article refers to this circular as the basis for the clarifications provided.

According to the article, when a transporter's godown is declared as an additional place of business by the consignee or recipient taxpayer, the transportation under the e-way bill is considered concluded once the goods reach the transporter's godown. However, e-way bill provisions will still apply when goods move from the transporter's godown to any other place of the consignee or recipient taxpayer.

The article mentions that the textile industry had requested to treat transporters' godowns as "transit godowns" due to the difficulty faced by transporters in complying with GST regulations. Treating these godowns as transit godowns may simplify the process and reduce the compliance burden for transporters and consignees or recipients.

The article cites the following legal provisions: - Rule 138 of the CGST Rules, 2017, which makes e-way bill generation mandatory for any movement of goods. - Section 2(85) of the CGST Act, 2017, which defines the term "place of business." - Section 35 of the CGST Act, 2017, which requires transporters to maintain accounts and records as warehouse keepers. - Rules 56 and 57 of the CGST Rules, 2017, which outline the record-keeping requirements for consignees or recipients.