Sr. No. Name of Members Profession Zone
1 Bishwaraj Agarwal Adv. East
2 Shekhar Patra Adv. East
3 Sandeep Kumar Tandon CA. North
4 Sanjay Saxena CA. North
5 Ram Narayan Suthar TC Central
6 Rajasthan High Court Advocate’s Association Corp. Mem. Central
7 Ketan Sheth CA. West
8 Deepak Joshi CA Central
9 Arun Joshi Adv. Central
10 Rohit Shah CA West
11 Ashok Sanchety CA. Central
12 Dinesh Boob Adv. Central
13 Deepak Arora CA. Central
14 Bhavin Parekh CA West
15 R. B. Virapannavar TC South
16 Jay Mathuria CA West
17 Nirav Sukhadia CA West
18 Vijay Kumar Joshi Adv. Central
19 Kunda Rama Narayana CA. South
20 Manoj Kumar Jain CA. Central
21 Jignesh Kansara CA. West
22 N. D. Baskaran I.T.P. South
23 Mradul Kumar Arya Adv. Central
24 Sanjay Kumar Jain CA. Central
25 Vijay Agarwal CA. East
26 Dinesh Gupta Adv. East
27 Gaurav Agarwal CA. East
28 Manoj Nahata CA. East
29 Bharat Purohit Adv. East
30 Pranati Mohanty Adv. East
31 Adarsh Agarwal CA. East
32 Amal Dey Adv. East
33 Shyam Sunder Singhvi CA. Central
34 Gagan Deep Singh CA. North
35 Subhash Kumar Adv. East
36 Hasmukh Kundalia Adv. East
37 Subhash Chandra Mishra Adv. Central
38 Bineet Sundriyal CA. North
39 Mayur Garg CA. Central
40 Mohammad Aslam CA. Central
41 Sushil Yadav Adv. East
42 Tushar Sodani Adv. Central
43 Chetan Khandelwal CA. Central
44 Dinesh Bohra Adv. Central
45 Anuja Bhura CA. East
46 N. G. Brothers Associate Mem. East
47 Shrikant Kedia T.P. Central
48 Ghufran Majid Adv. North
49 Deepak Kumar Gupta Adv. North
50 Deepak Agarwal Adv. North
51 Ashish Kapoor Adv. North
52 Rajdeep Goyal Adv. North
53 Sanjay Kumar Verma Adv. North
54 Venugopal Heda GSTP South
55 Mahesh Pichuka GSTP South
56 A. S. Narayana Swami CA. South
57 V. V. Satyanarayana Murty Upadrasta GSTP South
58 Venkata Raman Madugula GSTP South
59 Sesetty Chanti Babu S.T.P. South
6 Debojit Senapati Adv. East
61 Venugopal C. Adv. South
62 Mayank Sahewalla Adv. East
63 Indranil Chandra Adv. East
64 Ajoy Kumar Chand Adv. East
65 Nagesh Bajaj CA. North
66 K. V. M. Nageswara Rao S.T.P. South
67 D. Rama Rao Adv. South
68 Pasupu Reddy Kasi Viswanadham S.T.P. South
69 Sujaya Putchala GSTP South
70 Arijit Chakrabarti Adv. East
71 Navin Agrawal T.P. Central
72 Chetan Patel Adv. East
73 Naveen Garg CA. East
74 Zeehan Islam Adv. East
75 Satish Gidwani CA. West
76 Aditya Gupta CA. West
77 Sachin Betharia Adv. West
78 Prateek Sahni Adv. North
Sr. No. Name of Members Profession Zone
1 Paras Didwania CA. East
2 Mahabir Agarwala CA. East
3 Vinod Kumar Lohia I. T.P. East
4 Manoj Kumar Agarwala CA. East
5 Arun Agarwal Adv. East
6 Bikash Agarwala CA East
7 Amit Kumar Agarwala CA. East
8 Binit Todi CA. East
9 Gyan Chand Jain Adv. East
10 Rajesh Agarwalla Adv. East
11 Milind Hendre T.P. West
12 Prashant Waichal T.P. West
13 Harsh Jain CA Central
14 Neelav Dutta Adv. East
15 Pratyush Das Adv. East
16 Satyabrata Tripathy Adv. East
17 Tarun Agrawal I. T. P West
18 Avinash Singhal T.P. North
19 Vinay Kumar Jain Adv. Central
20 Rohit Bajoria Associate Mem. East
21 Vikash Sharma Adv. East
22 Mahendra Nath Dubey Adv. North
23 Kailash Bapna CA West
24 Jeetendra Kumar Gupta Adv. East
25 Om Prakash Chandak CA. East
26 Hitesh Chandak CA. East
27 V. Gopi T.P. South
28 Ravichandran Sambanthan T.P. South
29 Ramesh M. T. P. South
30 Ashwin Shah CA. West
31 U. Satyanarayana Raju T. P. South
32 K. Raja Rao Adv. South
33 V. Kesava Kalyana Babu Adv. South
34 Anand Kumar Jaiswal CA. South
35 Santosh Kumar Jaiswal CA. South
36 Braham Prakash Mundra CA. Central
37 Rajesh Agarwala Poddar CA. East
38 Bikash Pathak Adv. East
39 Satish Laddhad CA. West
40 Vinod Batra CA. West
41 Anil Verma Adv. North
42 Ajeet Agarwal CA. Central
43 Sashank Dundu Adv. West
44 Praveen Agrawal T.P. Central
45 Prateek Agrawal Adv. Central
46 Mohan Das Kabra Adv. Central
47 Manmohan Sahu Sonkalihari Adv. Central
48 Aditya Beria Adv. East
49 Ashok Kumar Agarwala CA. East
50 Pankaj Kumar Poddar Adv. East
51 Vivek Goel T.P. East
52 Shambhu Kumar Singh Adv. East
53 Pramod Kumar Agarwal Adv. East
54 Swamagat Pranam Sharma Adv. East
55 Mukesh Kumar Sinha Adv. East
56 Ashish Maskara CA. East
57 Dharmendra Jain Adv. East
58 Mohit Sankhla CA. East
59 Rakesh Dudharia CA East
60 V. Meenakshi Sundar CA. South
61 Nitin Gupta CA North
62 Kaushal Surti CA. West
63 Shiv Narayan Gupta CA. North
64 P. Murthi T.P. South
65 K. V. J. L. N. Sastry Adv. South
66 K. Siva Rama Krishna Adv. South
67 Hitesh Jain CA. South
68 U. Venkatesh Adv. South
69 C. Reddemma T.P. South
70 M. Venkata Subbaiah T.P. South
71 Senthil A. Adv. South
72 Pritesh Patil CA South
73 Abhay Chhajed CA. Central
74 Subhash Chandra Dhamor CA. Central
75 Satya Sarathi Das Adv. Central
76 Manoj Sharma CA. Central
77 Pramod Kumar Agrawal Adv. East
78 Shweta Sahewalla Bawari Adv East
79 Babita Goyal Sharma Adv. East
80 Subrata Kumar Das Adv. East
81 Ajay Gupta CA. North
82 Naga Chandra Devi Allada GSTP South
83 S. Chocklingom GSTP South
84 S. Senthilnathan GSTP South
85 Ayush Gupta CA. Central
86 Shyama Prasad Bhuyan Adv East
87 Prasanta Kumar Satapathy Adv. East
88 Shital Prasad Pani Adv. East
89 Anil Kumar Pattnaik Adv. East
90 Subhranshu Sekhar Das Adv. East
91 Trailokya Nath Satapathy Adv. East
92 Kailash Chandra Sahoo Adv. East
93 Raju Akurati GSTP South
94 Rownak Jajodia CA. East
95 Jayanti Prasad Khaitan Adv. East
96 Gopal Kishan Tiwari Adv. Central
97 Pradeep Jain CA. Central
98 Ajit Kumar Pradhan Adv. East
99 S. Krishnan Adv. North
100 Dhanraj H. Suthar CA. West
101 G. Murali Mohan GSTP South
102 Ravi Kumar Patwa CA. East
103 Laxman Kumar Kashyap GSTP Central
104 Surendra Kumar Rungta CA. Central
105 Kshitij S. Bafna CA. West
106 Nilesh Menezes GSTP West
107 Prabash Kumar Barik Adv. East
108 Atul Nathani GSTP West
109 Vimalchand Jain CA. West
110 Swati Ghatalia Adv. West
111 Davinder Singh CA. North
112 Ashok Sekhri Adv. North
113 Sanjay Sharma Adv. North
114 Om Prakash Rathi CS East
115 Sandeep Sharma CA. East
116 Gopal Singhania CA. East
117 Brajesh Sharma Adv. East
118 Pradip Kumar Nayak Adv. East
119 Sushil Goyal CA. East
120 Ram Gopal Prasad Adv. East
121 Bikram Kumar Sahu Adv. East
122 Pooja Talwar Adv. North
123 Simardeep Singh Adv. North
124 Anup Aggarwal Adv. North
125 Darshan Tanna G.S.T.P. West
126 Rahul Kabra CA. East
127 Shreya Agarwal CA. East
128 Vishal Agarwal CA. East
129 Pankaj Kumar Bhura Adv. East
130 Saiprakash Desai Adv. South
Sr. No. Name of Members Profession Zone
1 Lalit Kumar Jhunjhunwalla CA East
2 Ketan Shah T.P West
3 Sandeep Agrawal Adv. Central
4 Amita Bissa CA Central
5 Himanshi Chouhan CA. Central
6 Gajanand Verma Adv Central
7 Shankar Bharadhwaj CA West
8 Umesh Prasad Adv. East
9 Amar Paul T.P East
10 Pankaj Middha Adv. North
11 Suryakant Mishra Adv. Central
12 Satya Jayadeva Kumar Meda T.P South
13 Ishant Gupta Adv. North
14 Pushpendra P. Khandelwal CA Central
15 Vishal Virendra Singh CA North
16 Arun Gupta Adv North
17 Krishna Vijay Ladha CA West
18 Ashish M. Chaudhary CA North
19 Virendra Sampatraj Bothra T.P Central
20 V. Venu Gopala Gupta T.P South
21 Arun Kumar Agarwal Adv. North
22 Ujjwal Goel Adv. North
23 Luna Pradhan Adv. East
24 Lalit Kumar Shroff CA East
25 Praveen Kumar Shroff CA East
26 Nitin B. Bansal CA East
27 Umrao Singh Yadav Adv. Central
28 Meenal Pankaj Ghiya Adv. Central
29 Ashish Kumar Agrawal CA East
30 Rinav Ashok Khakhar T.P West
31 Sita Ram Jindal T.P Central
32 Vikas Puri Adv. North
33 Vandana Vershi Dodhia CA West
34 Roshan Kumar Adv. East
35 A. Subash Raj T.P South
36 Akhilesh Anilkumar Sharma Adv. Central
37 Rakesh Kumar Shishodia Adv. Central
38 Jayachitra Sivaprakash T.P South
39 Ramesh Kumar Maharaj Adv. South
40 Hitesh Sachar Adv. North
41 Narendra Nath Sen Adv. East
42 Dhruv Pankajkumar Khambhati CA West
43 P. Venkata Ramana Kumar CA South
44 Kamalkumar H. Valecha Adv. Central
45 Shantnu Gupta Adv. North
46 Sarthak Kumar Nema Adv. Central
47 Abhishek Sharma CA Central
48 Ramkishan Bang Adv. Central
49 Sitarama Satyasrinivas Bhetalam T.P South
50 Hemang Gargieya Adv. Central
51 V. Senthil Kumar Adv. North
52 Sushil Laxmandas Chandwani CA West
53 Bhavesh Chandrakant Bhuptani Adv. West
54 Rakesh Kumar Adv. East
55 Yashpal Jain CA North
56 Tej Narayan Gami Adv. East
57 Rajiv Kumar Adv. East
58 Nakul Agrawal T.P Central
59 Swapnil Megotia T.P East
60 Laxmidhar Tripathy Adv. East
61 Vijai J T.P South
62 Gautam Sharma CA Central
63 Karthikeyan R. T.P South
64 Praveen Gupta Adv. Central
65 Praveen Dave GSTP Central
66 Chanchal Kedia Adv. East
67 Manju Lata Shukla CA. East
68 Rahul Thakar Adv. West
69 Miki More CA. East
70 Bipul Kumar Talukdar Adv. East
71 Rajesh Agarwala CA. East
72 Manish Kumar Tharad Adv. East
73 Arpit Mathur Adv. Central
74 Manoj Kumar Karna Adv. East
75 Piyush Baid I. T.P. East
76 Siddharth Baghmar CA. Central
77 Sampurna Kumar Patro Adv. East
78 Aman Kedia CA. Central
79 Balasubrahmanya Narayan Rao CA. West
80 Tanmay Mody GSTP West
81 Chandigarh Chartered Accountants Taxation Association Association North
82 Kakaria & Associates Corporate West
83 Virendra Jain Adv. Central
84 Radha Raman Khatuwala Adv. East
85 Kunal Jajodia CA. East
86 Manubhai Vaghela Adv. West
87 Virendra Popat T.P. West
88 Pradip Kumar Agarwal CA East
89 Trilochan Mohapatro Adv. East
90 P. Uma Shankar Reddy Adv. South
91 Sanjay Kumar Jain CA. East
92 Rasmi Ranjan Padhi Adv. East
93 Pradip Kumar Yadav Adv. East
94 N. Nageswar Rao Adv. East
95 Rajeev Kumar Agarwal CA. East
96 Gopal Rohra I.T.P. West
97 Pankaj Jain I.T.P. North
98 Raman Kumar Sharma Adv. North
99 Raghavendra T. N. CA. South
100 Sanjaya Kumar Sahu Adv. East
101 Rani Ratti CA. West
Sr. No. Name of Members Profession Zone
1 Soumen Roy Adv. East
2 Uttam Kumar Roy Adv. East
3 Sanjay Kumar Agarwal Adv. East
4 Subhendu Kumar Dhal Adv. East
5 Surendra Prajapati Adv. East
6 Sanjay Kumar Mishra Adv. East
7 Arun Kumar Dash Adv. East
8 Bimal Kumar Praharaj Adv. East
9 Mansukh Waghela T.P. West
10 Vivek Chiraniya CA. East
11 V. Sakthivel T.P. South
12 P. Suresh CMA South
13 Pradipta Kumar Rout Adv East
14 Padmanabha Bisi Adv. East
15 Sabyasachi Pradhan Adv. East
16 Shripal Luniya CA. Central
17 Jatin Bhatt Adv. West
18 Rishabh Mishra T. P. North
19 Arpita Mukherjee Adv. West
20 Pramod Jain CA. West
21 Ajaya Kumar Tripathy Adv. East
22 Kamlesh Hamir Dalal Adv. West
23 Arvind Sikaria Adv. North
24 M. Naveenkumar CA. South
25 Mohit Aggarwal CA. North
26 Shashank Singhal CA. North
27 Jitendra Kumar Mishra Adv. Central
28 Vijay Kant Mishra Adv. Central
29 Jaykishan Rathi CA. West
30 Dr. Subroto Roy Adv. North
31 Neha Gupta CA. North
Sr. No. Name of Members Profession Zone
1 Srikant Singh Adv. East
2 S. Babu Adv. South
3 Vivek Kumar Verma Adv. Central
4 Dinesh Saini CA. East
5 Bhuvnendra Varshney Adv. North
6 Amit Kumar Gupta CA. North
7 Arun Agarwal CA. North
8 Atika Agarwal CA. East
9 Sagar Tank CA. West
10 Vimal Kumar Gupta Adv. North
11 Pankaj Kumar Shukla Adv. North
12 Himanshu Kesarvani Adv. North
13 Abdul Rauf Ansari Adv. North
14 J. Attaulla T.P. South
15 Kishore Kunal Adv. North
16 Pratik Niyogi CA. South
17 Anuj Singhal Adv. North
18 Deepak Khandelwal CA. Central
19 Piyush Singhal Adv. North
20 Vipin Chnadra CA North
21 Anand Kumar Singhal Adv. North
22 Alagappa Pillai T.P. South
23 Gautam Datta Adv. East
Sr. No. Name of Members Profession Zone
1 Vikash Kumar Jain CA. East
2 K. S. Murali Krishna TC. South
3 Om Prakash Nayak Adv. East
4 R. Sathishkumar T.P. South
5 Karan Kumar Teli T.P. South
6 Anilkumar K. Jayswal Adv. West
7 Vikash Kumar CA. East
8 Mukesh Soni Adv. Central
9 Aakash Kumar Adv. East
10 Sachin S. More T.P. West
11 Ajaz Ahmed Butt T.P. North
12 Rahul Agarwal CA East
13 Biplob Mohonta T.P. East
14 Manish Agarwalla CA East
15 Soubhagya Ranjan Biswal Adv. East
Sr. No. Name of Members Profession Zone
1 Kamal Kumar Kothari CA. East
2 Bikash Kumpawat CA. East
3 Sujeet Kumar Agrahari CA. North
4 Suresh Kakkar Adv. North
5 Jayesh Joshi Adv. Central
6 Pankaj Garg CA. East
7 Omprakash Agarwalla CA East
8 Arun Kumar Jajodia CA. East
9 Dwijendra Nath Mondal Adv. East
10 J. N. V. Suresh Kumar Adv. South
11 Sanjiv Gangadhar Brahme CA. West
12 Adarsh Kediya CA. East
13 Rohit Poddar Adv. East
14 Gawesh Narula GSTP North
15 Sohil Ganeriwala CA. South
16 Debabrata Acharjee Adv. East
17 Ramesh Rathi CA. East
Sr. No. Name of Members Profession Zone
1 Ajit Kumar Jain CA. West
2 Ved Pakash Rout Adv. East
3 Sanjeev Kumar Agarwal CA. North
4 Vikash Rathi Adv. East
5 Manishkumar R. Shah Adv. West
6 Akshay Rajendra Shah CA. West
7 Ritesh Kumar Jain CA. Central
8 Sahadev Mandal Adv. East
9 Deven Shridhar Gujar T.P. West
10 Nisha Singh CA. North
11 Jagjiwan Lal CA. North
12 Ashish Mashruwala Adv. Central
13 K. Rajan T.P. South
14 Saurabh Kapoor Adv. North
15 Ranjit Sharma Adv. North
16 Lokesh Kumaran Adv. South
17 C. Tejonidhi T.P. South
18 Rahul Srivastava Adv. North
19 Ganesh Rajgopalan CA West
20 Navneetlal Bora T. P. West
21 Sunanda Chakraborty T.P. East
22 Vinay Goenka CA. East
23 R. K. Suchindra CA. South
24 Harsha S. Patel T.P. South
25 Deepak Bholusaria CA. North
26 Mansoor M. Sanji T.P. West
27 Shiv Shankar Sharma Adv. East
28 Rajiv Kumar Gupta Adv. North
29 Aditya Khandelwal Adv. North
30 Ashim Kumar Basu Adv. East
31 Ravi Shekhar Gupta Adv. East
32 Akashdeep Singh CA. North
33 Immanuel Clements C. CA. South
34 Bharath Lakshminarayana Adv. South
35 Pramod Kumar Sinha Adv. East
36 Sathupalli Nagabhushanam T.P. South
37 N. S. Rao Adv. South
38 Ravish Chandra Tiwary Adv. East
39 B. Ramkumar Corp. Mem. South
40 Laxmi Narayan Sharma Adv. East
41 Rohit Kumar Agarwalla T.P. East
42 G. Nagarajan GSTP South
43 P. Gopi Krishna GSTP South
44 Avish Mahajan CA. North
45 Sanjay Goyal CA East
46 Md. Jawed Hassan Khan Adv. East
47 Devendra H. Jain Adv. West
48 Vinayak R. Velhankar CA. West
49 Rajendra Khadilkar GSTP West
50 Malay Kansa Banik Adv. East
51 Sushil Kumar Jain CA. North
52 Vivek Bubber CA North
53 Siva Ramanjaneyulu Repakula GSTP South
54 Parasmal C. Chhajer CA. South
55 Anand Gupta Adv. Central
56 Pranav P. Sheth Adv. West
57 Pravin Jain CA. West
58 Anurudra R. Chavan Adv. West
59 Daitari Behera Adv. East
60 Amit R. Panchal GSTP West
61 Bhabu Murthy J. S. Adv. South
62 Kanhaiya Lal Tulsyan Adv. North
63 Anup Agarwalla T.P. East
64 Ranjit Karmakar Adv. East
65 Vipul Soni Adv. Central
66 Komal Agrawal CA. Central
67 Piyush Bafna CA. West
68 Rakesh Ratilal Jain STP West
69 Narendra Sonawane STP West
70 Manojkumar S. Chitalikar STP West
71 Prasad G. Deshpande STP West
72 Samir Kanabar CA. West
73 Prabhansh Sharma Adv. Central
74 Sharad Suryawanshi STP West
75 Pooja Saha T.P. East
76 Sanjay Budhia Adv. East
77 Dilip L. Phadke Adv. West
78 K. Shanmukha Sai CA. South
79 R. Venkat Sai Sesh Aditya CA. South
80 S. Saravanan Adv. South
81 Sudhansu Sekhar Das Adv. East
82 Bhamesh Kumar Goel Adv. North
83 Pankaj Kumar Agarwal T.P. Central
84 Smriti Agarwal Cost Accountant East
85 Kunwar Dayal Singh Jaggi Adv. North
86 Shital N. Gujarathi CA. West
87 Rajnish Khanna CA. North
88 Siddharth Havale Adv. West
89 Sharnam Legal Corp. Mem. North
90 Ashu Dalmia CA. North
91 Shripad S. Bedarkar Cost Accountant West
92 Keshav Pareek CA Central
93 Yash Nagar CA. West
94 Arun Kumar Mishra Adv. North
95 Vaibhav Siroliya Adv. Central
96 Nagesh Dubey Adv. East
97 Kumar Ramakant Sinha Adv. East
98 Krishna Murari Singh Adv. East
99 Prashant Limaye Associate Mem. West
100 Manav Poddar Adv. East

The movement of consignments from source to destination in an efficient manner is the key for development and success of economy. Infrastructure as well as facilities involved for multimodal transport in the commercial world in India needs to be supported by the robust digital infrastructure for seamless movement of consignments and recording of transactions as well as their intelligent verification ensuring compliance of law. Proper recording of every transaction is a need for healthy competitive business where there is no scope for unhealthy competition due to possibility of tax evasion. The integrated solution having required attributes is also necessary for the collection of proper and correct taxes essentially needed for the citizens of the country.

The ‘Goods & Services Tax’ no doubt has been planned with this objective and probably after initial hiccups it may stabilise and very soon achieve the goals. The “self-policing mechanism” i.e., matching of outward supply with the inward supply and consequently ensuring correct claim of ITC as well as due payment of tax by one and all was proclaimed as one of the effective advantages of GST. During the planning stage for GST it was propagated by the policy makers that all the check-posts on the borders of the States will go away and there would be seamless movement of goods from one corner to another corner of the country. This idea was well received not only by Trade & Industry but also by the Transport and Logistic sector, it was expected that in the GST regime the system of movement of goods and doing business in the country is going to tremendously change. Everybody of us was in great hope……, but this hope was shattered as some of the States could not accept this idea, as administration was notable to garner the required trust of business and industry to implement GST without ‘e-way Bill’.

Suddenly, the idea of ‘National E-Way Bill’ cropped-up and hurriedly legal provisions now contained in Section 68 of CGST Act, 2017 and Rule 138 to 138-D of the CGST Rules 2018 were framed and incorporated into draft GST law just before the start of so called very short public debate. At that time also the policy makers and law framers re-assured the Trade & Industry including Transport and Logistics sector that the new system of GST would ensure hassle free and seamless movement of goods throughout the country. The question that arises ‘Why E-Way Bills’?

The ideal situation as well as one of the prime aim of introduction of GST in the country as “Tax Reform” was to make movement of goods easy and hassle free without any need of personal intervention by the Officers of the Tax Check-Posts or on Road by the Officers of Mobile Squad.

Since, e-Way bill is introduced by Rule 138 of the CGST Rule, 2018 the other provisions such as following comes into play:

Rule 138-A which prescribes – Documents and Devices to be carried by a person-in-charge of the conveyance or Rule 138-B which prescribes-Verification of documents and conveyance or

Rule 138-C which prescribes – Inspection and verification of goods or

Rule 138-D which prescribes – Uploading of information regarding detention of vehicle etc.

Without these gripping provisions under GST Act there is no point for prescribing ‘e-Way Bill’. Thus, once these draconian provisions have been placed on the statute whereby total tax along with equivalent amount of penalty i.e. 200% of the basic tax amount is required to be forcefully deposited for release of the consignment and vehicle, such powers are bound to be misused by inspectors or officers on road in the Mobile Squad due to the discretion and availability of opportunity of personal interaction. Removing the check posts in GST be then just an eye wash and nothing more.

Just to give a simple and live example in the State of U.P., since 9th February 2018 large number of consignments were detained throughout the State by the Mobile Squad Officers only for the reason that ‘U.P. E-Sancharan Form’ was not available with the inter-state consignment even though the optional ‘National E-Way Bill’ was very much available with the consignment. More than 300 transporters or business dealers have gathered courage to approach Hon’ble Allahabad High Court for release of consignment without deposit of the required 200% of the amount of basic tax (IGST) even though there was no effective Notification prescribing verification of inter-state movement of goods from one State to another State. It is important that Hon’ble High Court has repeatedly ordered to release such consignments and vehicle without the deposit of cash and bank guarantee. The top administration of the State of U.P. is still allowing this wrong and illegal practice since 9th February 2018 which is against the spirit of seamless movement of consignments in GST.

If such type of attitude/ approachcontinues in GST regime by same set of Administrative Officers who were earlier responsible to check the consignments in the erstwhile Trade Tax or VAT regime then probably one of the major objectives of implementation of GST will be frustrated and the positive effects will not be available to the Indian economy. Not only Central Government, but every State needs to frame such law and procedures, so that it could not be misused by anybody including the officials in the larger interest of the economy and nation.

The requirement and system of ‘e-Way Bill’ could be dispensed with if “GSTN IT platform”of the Government ensures the correct matching of ‘Tax Invoices’ as recorded by the outward supplier and the inward recipient of the goods. Unfortunately, due to the reasons known to the Government in spite of GST in place for more than eight months, GSTN system has not yet taken any information of inward supply i.e. purchases etc. including Input Tax Credit in GSTR-2. Probably the inefficiency of the Government IT Platform is forcing the requirement of introduction of the system of ‘National E-Way Bill’. Unfortunately, it is at the detriment of honest & fully complied tax payers.

Had there been a mandatory requirement as envisaged in GST Law of additionally uploading of “Tax Invoice” through Official Web Portal of the Government then there would have been no distinct need of creation of ‘e-Way Bill’. This will not only eliminate the burden on the official web portal for separately issuing ‘e-Way Bill’ for every transaction of ₹ 50,000/- or more for which ‘Tax Invoice’ has already been issued and recorded by the supplier. This will also save the precious time consumed by the employees of Trade & Industry including Transporters avoiding duplicity of work and possibility of wrong punching of any information while generating ‘e-Way Bill’. Further it will also save time and burden of again uploading of invoice data on web portal at the time of furnishing monthly returns i.e. GSTR-1 which will also relive burden on IT platform making it comparatively free during the last days of return filing.

To my mind the advantages as claimed by bureaucracy in favour of the requirement of ‘e-Way Bill’ are much less than the disadvantages in the shape of repetition of work as well as enhanced burden on IT Platform. Every action entails some cost to the stake-holder which is an avoidable burden on economy making transaction more cost effective, this should be considered by the policy makers in the larger interest of competitive business.

The biggest advantage as assumed and propagated by the administrationis to stop the multiple reuse of the same ‘Tax Invoice’ on the same day for movement of more than one set of similar goods specially for the short distances across the borders of the states as the consignment is covered under ‘e-Way bill’, but my strong apprehension is that the procedure prescribed under Rule 138 to 138-D under Notification No. 12/2018 – Central Tax dated 7-3-2018 this aim could not be achieved as this notification provides that the cancellation of ‘e-Way Bill’ is possible within 24 hours by the supplier as well as rejection of ‘e-Way Bill’by the recipient within 72 hours, this unscrupulous method may be adopted to hide the multiple transaction,so the aim to check the repeated movement of goods under one set of documents cannot be achieved by the newly designed system of ‘e-Way Bill’. It is required that the fast and efficient digitally supported system should be put in place under which the transaction is automatically verified through RFID Tag for the individual consignment or group of consignments loaded in any mode of transportation without physical intervention or stoppage of vehicle.

The most important issue in GST concerning the ‘e-Way Bill’ is that this system is adversely impacting the basic philosophy of the Government of minimal interaction between taxpayer and the tax controller/tax inspectors. The philosophy of the present Government of minimal contact to avoid corruption seems to be not achieved, this may be against the roadmap of corruption free India. Apart from this issue, the Government with open heart have considered many suggestions of Trade & Industry including Transporters & Logistics Sector to provide better and unambiguous procedures in the reintroduced ‘National e-Way Bill’ system under certain eventualities which may avoid many practical difficulties.

In the era of multimodal transportation the Government has to certain extent already envisaged the practical requirement that consignments may take various modes like Road, Rail, Water-ways, Sea or Air during its transportation from source to destination and thus provided in ‘Rule 138A(1)(b) proviso’that there is no requirement of ‘e-Way bill’ in physical form or ‘e-Way Bill’ number in electronic form or ‘E-way bill’ mapped on RFID device embedded on the conveyance when the goods are moving by rail or air or vessel. So only e-Way bill is required to be kept by the in-charge of the vehicle when the goods are transported on road. The railway has been placed under responsibility to deliver the goods only when the recipient furnishes the valid copy of ‘e-Way Bill’ for the consignment. Further the responsibility of generation of ‘e-Way Bill’ has not been casted on the shoulders of railways or airways or vessel companies while a transporter in addition to a registered person being the supplier or the recipient may generate ‘E-way Bill’ if authorized in that respect.

Further, the Transporter needs to be enrolled or registered on the ‘e-Way Bill Portal’ of the Government to update details of mode/conveyance of transport in Part–B of e-Way Bill 01 in respect of the transection under movement, each transporter will be allotted a TRANSID (a unique number like GSTIN) for identification, it is important to note that the transporter must declare the details of all the warehouses and offices on the ‘e-Way Bill Portal’ at time of obtaining TRANSID at GST Portal, this is necessary in order to avoid harassment from tax authorities during verification raids conducted at the warehouses or offices of the transport companies.

The well designed intelligent and integrated system of reporting and verification of commercial transactions based on a robust Information Technology Platform could be a great help for faster and smoother movement of goods in the era of multimodal transportation.

[Source : Article printed in the souvenir of 2 Day National Tax Conference held on 5th & 6th May, 2018 at Indore]