The changes, scheduled to take effect from August 1, require businesses to mandatorily provide the Goods and Services Tax Identification Number (GSTIN) of the final recipient of goods, known as the 'Ship-to GSTIN', in Bill-to/Ship-to transactions. In such transactions, the invoice is raised on one party (Bill-to), while the goods are delivered to another party/location of the same party (Ship-to). GSTN has also introduced a voluntary facility to close an e-way bill after the goods have been delivered.
People aware of the discussions said industry associations have urged the government to defer the rollout by three months, arguing that e-invoices and e-way bills are real-time compliances and that any such changes require modifications to source systems, enterprise resource planning (ERP) systems, processes, extensive testing, and communication to all stakeholders. This is important to ensure a smooth rollout and avoid any business disruption.
Industry representatives have also raised concerns over commercial confidentiality. They said businesses, especially those engaged in distribution, trading, contract manufacturing and merchant exports, may not want to disclose the GSTIN of their end customers to suppliers or transporters, as it could reveal sensitive business relationships.
Businesses have further pointed to practical difficulties in obtaining the Ship-to GSTIN from customers in real time. They warned that if this information is unavailable while generating an invoice, it could delay invoicing as well as the dispatch of goods.
Industry has also sought clarity on the legal implications of the new voluntary e-way bill closure facility. Under the new feature, suppliers, recipients, transporters or authorised persons can voluntarily mark an e-way bill as closed once the goods have been delivered. Businesses have asked the government to clarify whether any changes will be permitted after an e-way bill has been closed and whether there could be any compliance consequences for delayed or non-closure.
Prashanth Agarwal, partner, PwC India, said the proposed e-way bill changes would require modifications to companies' ERP systems and customer databases, for which businesses generally need more time to prepare and test the changes.
"...the GSTN should reconsider certain validations, particularly in Bill-to/Ship-to transactions where the billing and delivery locations may have the same GSTIN. Any changes to real-time compliance systems should be implemented only after adequate consultation with industry and sufficient preparation time. A transition period of at least three to six months would help businesses adopt the changes smoothly," he said.
On the proposed voluntary e-way bill closure facility, Agarwal said it reflects the government's focus on collecting data on the actual delivery of goods. "Companies should start strengthening their processes now, as the requirement could become mandatory in the future," he added.
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