This circular provides clarification on the applicability of e-way bill provisions where goods are temporarily stored in the godown or warehouse of a transporter, particularly addressing difficulties faced by the textile sector, weavers, artisans, and transporters.

It has been clarified that an e-way bill is required for the movement of goods from the supplier’s place of business to the recipient taxpayer’s place of business, and this requirement continues even when goods are temporarily stored in the transporter’s godown during transit. Such storage is treated as part of the movement of goods, and the goods must always be accompanied by a valid e-way bill until delivery is completed.

Where the recipient taxpayer stores goods in the transporter’s godown, the godown must be declared by the recipient as an additional place of business under the CGST Act. A simple declaration by the recipient taxpayer, with the concurrence of the transporter, is sufficient for this purpose. Once the transporter’s godown is declared as an additional place of business, the movement covered by the original e-way bill is deemed to be completed upon arrival of goods at that godown, and extension of e-way bill validity is not required.

Any subsequent movement of goods from the transporter’s godown to another place of business of the recipient taxpayer will require a fresh e-way bill, as per applicable rules. The transporter remains responsible for maintaining records as a warehouse keeper, and the recipient taxpayer must also maintain prescribed accounts, which may be kept at the principal place of business. These clarifications do not impose any additional compliance burden on transporters.