Understanding the NIC's Blocking and Subsequent Withdrawal of Blocking on E-Way Bill Generation
Introduction to Blocking:
• On 5th January 2024, the National Informatics Centre (NIC) announced the blocking of e-Way Bill generation without e-Invoice/IRN details for B2B and B2E transactions for e-invoice enabled taxpayers.
• To comprehend the withdrawal of this blocking, it's essential to first understand what the blocking entailed.
E-Invoice Applicability Basics:
• E-Invoice has been operational since October 2020 for taxpayers with an Annual Aggregate Turn Over (AATO) above Rs. 500 Crores.
• The system has been gradually extended to include taxpayers with AATO above Rs. 5 Crores.
Routine Practice of Taxpayers:
• Since its inception, e-Invoice has been seamlessly integrated with the e-Way bill system.
• e-Way bills are typically generated in conjunction with the e-Invoice.
• When transportation details are included in e-Invoice generation, an e-Waybill is automatically generated.
• Most taxpayers generate e-invoices along with e-way bills.
Exceptions to General Practice:
• Some taxpayers, eligible for e-Invoicing, have been found to generate e-Waybills without linking them with e-Invoices, particularly in B2B and B2E transactions.
• This leads to mismatches in certain parameters between the separately entered invoice details under e-Waybill and e-Invoice.
Reason for Blocking Advisory:
• To mitigate these mismatch situations, the NIC decided to block e-Waybill generation without e-Invoice details starting from 1st March 2024.
• This measure was applicable to e-invoice enabled taxpayers, specifically for B2B and export transactions. EWBs for other transactions like B2C and non-supplies were to continue as usual.
Withdrawal of the Decision:
• Despite the initial announcement, this decision was withdrawn by the NIC on 10th January 2024.
• No further details were provided regarding the withdrawal.
Our Recommendation:
• Ideally, both e-invoice and e-way bill should be generated together to avoid any discrepancies.
• The e-invoice is mandatory for B2B transactions and exports where the AATO exceeds Rs. 5 crore.
• Currently, there are no implications if an e-way bill is generated without IRN details.
• If the NIC's original advisory from 5th January 2024 had been implemented from 1st March 2024, it could have led to the blocking of e-way bill generation without an e-invoice.
• However, following the advisory's withdrawal, taxpayers can continue to generate e-way bills without IRN details until further notice from the NIC, though it is best practice to generate both documents simultaneously for data consistency.
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