Unregistered persons are also required to generate e-Way Bill. However, where a supply is made by an unregistered person to a registered person, the receiver will have to ensure all the compliances are met as if they were the supplier. Transporters carrying goods by road, air, rail, etc. also need to generate e-Way Bill if the supplier has not generated an e-Way Bill. Unregistered Transporters will be issued Transporter ID on enrolling on the e-way bill portal after which Eway bills can be generated.

Who Shall Generate E-Way Bill

  1. The persons responsible to generate the e-Way bill are: (i) The person causing movement of goods if consignment value exceeds 50,000/-:

Ordinarily, the consignor;Where the consignor is not a registered person, the Consignee;

(ii) The Transporter, where an e-Way bill has not been generated as cited supra in respect of movement of goods. 2. In case of inter-State movement of goods, irrespective of the value of goods, the following persons would be responsible for raising an e-way bill:

Principal/job worker;An unregistered consignor of handicraft goods for inter-State movement, who is exempt from registration under Section 24(i) and (ii);

  1. The registered person can authorize a transporter or e-commerce operator or a courier agency to furnish the information in Part A of Form GST EWB-01, on behalf of the registered person.
  2. Unregistered transporter can enrol on the common portal and generate e-Way bill on behalf of its customers;
  3. Any Person (unregistered recipient) can enrol & generate the e-Way bill for movement of goods for his/her own use
  4. Any person desirous of generating may voluntarily generate an e-Way bill even when value of consignment is lesser than 50,000 Rupees. If the goods are moved by unregistered person and handed over to the transporter for transportation of goods then either of them can generate an e-Way bill (EWB). The unregistered person can generate EWB as an unregistered person

Practical Intricacies

a. In cases of outward supply returns (sales returns), the customer or the transporter shall be the person causing the movement of goods and hence shall be responsible to generate the e-Way bill. b. In case of high sea sales, since the supply is effected before the goods cross the customs frontiers, an e-Way bill is not required. However, the ultimate buyer will be required to generate an e-Way bill (if the consignment value exceeds Rs. 50,000) to move goods from the port to the place of business. c. In case a customer is purchasing and moving the goods himself and the value exceeds Rs. 50,000/-, an e-Way bill can be generated by the taxpayer or supplier based on the invoice issued to him. The customer may also enroll as a citizen and generate the e-Way bill himself. d. In case the consignee or recipient refuse to take the delivery of goods, the transporter can get one more e-Way bill generated with the help of the supplier/recipient by indicating the supplies as sales return with relevant document. e. If the individual bills are less than Rs. 50,000/- but the total value of goods in a conveyance exceed Rs. 50,000/- the transporter shall be responsible / liable to raise an e-Way bill since the individual parties will not be liable to generate an e-Way bill. Note: If a transporter is transporting multiple consignments in a single conveyance, they can use the form GST EWB-02 to produce a consolidated e-way bill, by providing the e-way bill numbers of each consignment.

If both the consignor and the consignee have not created an e-way bill, then the transporter can do so * by filling out PART A of FORM GST EWB-01 on the basis of the invoice/bill of supply/delivery challan given to them.

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