Transportation of Goods Without Issue of Invoice
Rule 8(1) of draft GST Tax invoice, Credit and Debit Notes Rules provides that for the purposes of:
a) supply of liquid gas where the quantity at the time of removal from the place of business of the supplier is not known,
b) transportation of goods for job work,
c) transportation of goods for reasons other than by way of supply, or
d) such other supplies as may be notified by the Board,
the consigner may issue a delivery challan, serially numbered, in lieu of invoice at the time of removal of goods for transportation, containing following details:
(i) date and number of the delivery challan,
(ii) name, address and GSTIN of the consigner, if registered,
(iii) name, address and GSTIN or UIN of the consignee, if registered,
(iv) HSN code and description of goods,
(v) quantity (provisional, where the exact quantity being supplied is not known),
(vi) taxable value,
(vii) tax rate and tax amount – central tax, State tax, integrated tax, Union territory tax or cess, where the transportation is for supply to the consignee,
(viii) place of supply, in case of inter-State movement, and
• The purpose of “Supply of liquid gas where the quantity at the time of removal from the place of business of the supplier is not known” is not understood. If the purpose is to capture supply through pipelines or other conduit, it shall also include other goods such as chemicals, crude etc. Also, in case of pipeline supply carrying delivery challan for transportation is practically not possible.
• Point (iii) viz name, address and GSTIN or UIN of the consignee, if registered appears to be ambiguous and needs clarification.
• With respect to point (a) Supply of liquid gas where the quantity at the time of removal from the place of business of the supplier is not known if the purpose is to capture some other transactions, the same be clarified.
• In (iii) the wordings be name, address and GSTIN or UIN, if registered, of the recipient to align with the other provisions of the law and to provide clarity as the existing wording would create ambiguity as to whether the name and address of the recipient be included if he is not registered.
• Alternatively, it may be provided that there is no requirement to provide special treatment in case of liquid gas. With availability of credit note for stock loss after invoicing or other document in case of removal not involving supply, Rule 8 may not be required.