CA Final · Indirect Tax Laws
Accounts and Records; E-way Bill: CA Final Indirect Tax Laws
Accounts and Records covers what books a registered person must keep under GST, where, and for how long. An e-way bill is required when consignment value, including tax, exceeds ₹50,000, subject to exemptions and state-specific intra-state thresholds. Part A holds invoice details, Part B holds vehicle details. Solve questions by naming the rule, applying case facts, then concluding.
What this chapter covers
This chapter has two halves. The first half is about record-keeping. Section 35 of the CGST Act requires a registered person to keep accounts and records at the principal place of business, covering production or manufacture, inward and outward supplies, stock, input tax credit availed, output tax payable and paid, and other prescribed particulars. It also covers records kept in electronic form, and special records that agents, transporters and warehouse operators must keep.
The second half is about the e-way bill, the document that must travel with goods in movement. You need to know when it is required, who generates it, what goes in Part A and Part B, how long it is valid, when it can be cancelled, and what happens if a vehicle is intercepted without proper documents.
The chapter connects to the rest of Paper 5 in a practical way. Records are the source for returns, input tax credit claims and reconciliations. The e-way bill links to supply, invoicing and valuation, and the penalty part links to the wider theme of detention and seizure of goods in transit. Questions often put these together in one case scenario, so read this chapter alongside returns and ITC.
This chapter is compact, rule-based and predictable, which makes it good value for effort. Most of it is factual: who keeps what, where, for how long, what the validity period is, and what the consequence is of a breach. These are easy to score in the 30% case-scenario MCQs, and they fit the provision-facts-conclusion form of written answers. Students who learn the e-way bill timelines and conditions precisely can score well on short practical cases that others lose through vague answers.
Accounts and Records; E-way Bill: topics in the order to study them
- 1Accounts and Records under Section 35 of CGST ActThis is the base rule on what records a registered person keeps and where, so everything else in the chapter builds on it.
- 2Generation and Maintenance of Electronic RecordsIt extends the base rule to records kept in electronic form, so read it right after you know what must be kept.
- 3Audit and Special Records under GSTSpecial records for agents, transporters and warehouse operators are exceptions to the general rule, so learn them once the general rule is clear.
- 4E-way Bill: Applicability and DocumentsYou must know when an e-way bill is needed and which documents support it before you learn how it is generated.
- 5Generation, Validity, Cancellation and Part B UpdatingThis is the working procedure and the most number-heavy part, so it comes once applicability is clear.
- 6Inspection, Verification and Penalty for E-way BillIt deals with what happens when the earlier rules are broken, so it works best as the last topic.
How to prepare Accounts and Records; E-way Bill
Treat this as a two-part chapter: a short record-keeping part to understand, and an e-way bill part to learn with exact conditions and timelines.
- Read the section on accounts and records once and list in your own words the items that must be kept, the place of keeping and the retention period.
- Learn the special records for agents, transporters and warehouse or godown operators as a separate short list, and note how they differ from the general rule.
- Make a one-page table for the e-way bill: who generates it, when it is needed, the ₹50,000 consignment value threshold (including tax), the exemptions and state-specific intra-state thresholds, Part A contents, Part B contents and the validity rule.
- Practise validity by calculation. For regular cargo, take a distance and apply one day for each 100 km or part thereof. For over-dimensional cargo, apply one day for each 20 km or part thereof. Then check your answer against the rule for extension.
- Write out a short case for each of cancellation, Part B updating and interception, and answer it in the form provision, facts, conclusion.
- Read the official text of the latest rules and notifications for thresholds, exemptions and limits, since these are updated from time to time.
- Finish with mixed case-scenario MCQs and time yourself, because the 30% case-based MCQs have no negative marking and reward quick, accurate reading of facts.
Common mistakes in Accounts and Records; E-way Bill
Stating the e-way bill threshold without conditions, as if it applied the same way to every movement.
Fix: Write the rule with its trigger: movement of goods in a consignment above the threshold, then check the case facts for value, document and reason before concluding.
Miscalculating validity by treating a part of 100 km as zero extra days.
Fix: For each 100 km or any part of it, count one day. Work the distance in steps and write the calculation in your answer.
Mixing up Part A and Part B contents.
Fix: Remember Part A as invoice and consignment details and Part B as vehicle details. Part B is what is updated when the vehicle changes.
Cancelling an e-way bill after the permitted time or after verification in transit.
Fix: Write both limits in every cancellation answer: within 24 hours of generation, and not if the goods have been verified in transit.
Writing general record-keeping answers without naming the specific items or the retention period, or stating 72 months as the only rule, or citing Section 35 for retention.
Fix: List the items required under Section 35 and the place of keeping. Then cite Section 36 for retention and state it in full: 72 months from the due date of the annual return for the relevant year. Where there is an appeal, revision, other proceedings or a pending investigation, add that records are kept for one year after final disposal, or for the 72 months, whichever is later. Then tie it to the facts.
Quoting thresholds, exemptions or penalty amounts from memory without checking the latest official text.
Fix: Verify every figure against the current official text before the exam, and keep a dated one-page list of what you have confirmed.
Last-day revision: Accounts and Records; E-way Bill
- Accounts and records are kept at the principal place of business, and also at the additional places of business as the law requires.
- Records cover production, inward and outward supplies, stock, ITC availed, output tax payable and paid, and prescribed particulars.
- Under Section 36 of the CGST Act, records are retained for 72 months from the due date of the annual return for the relevant year. If the person is a party to an appeal, revision or any other proceedings, or an investigation is pending, the records must be kept for one year after the final disposal of those proceedings, or for the 72 months, whichever is later.
- Electronic records must be maintained in a form that is secure, retrievable and, where required, authenticated.
- Agents, transporters and owners or operators of godowns and warehouses have their own special record obligations.
- An e-way bill is required when the consignment value exceeds ₹50,000. This value includes tax. Exemptions (for example, specified exempt goods) and state-specific thresholds for intra-state movement apply.
- Part A of the e-way bill holds invoice-level details, and Part B holds vehicle or transport details.
- Validity of an e-way bill for regular cargo is one day for every 100 km or part thereof. For over-dimensional cargo it is one day for every 20 km or part thereof.
- An e-way bill can be cancelled within 24 hours of generation if goods are not moved or details are wrong, and not after verification in transit.
- The person in charge of the conveyance must carry the invoice or other prescribed document and the e-way bill.
- Under Section 129 of the CGST Act, goods in transit or in storage without the right documents can be detained. For taxable goods, if the owner comes forward, the penalty is 200% of the tax payable. If the owner does not come forward, the penalty is 50% of the value of goods reduced by the tax amount paid on them. For exempt goods, if the owner comes forward, the penalty is 2% of the value or ₹25,000, whichever is less. If the owner does not come forward, it is 5% of the value or ₹25,000, whichever is less.
Accounts and Records; E-way Bill practice questions
- Sunrise Pharma Ltd stores its accounts in password-protected, coded files. On demand, the officer asks for access to the files. Which set of…
- During an inspection at the Pune office of Kulkarni Components Ltd, a registered person storing all accounts electronically, the proper offi…
- Mehta Exports LLP stores its accounts in a customised accounting package that uses internal codes for ledgers and items. On demand by the pr…
- Himalaya Pharma Ltd stores its accounts in password-protected electronic files using internal codes for product groups. On demand, the offic…
- Which of the following correctly describes the format in which a registered person who maintains electronic records may produce the relevant…
- Sundaram Textiles Pvt Ltd, a registered person in Coimbatore, keeps all its books of account on a cloud-based accounting system. A server cr…
- Sundaram Textiles Pvt Ltd, a registered person in Coimbatore, keeps all its accounts and records in electronic form on a server at its facto…
- Kaveri Auto Components Ltd stores its books of account in an accounting software on a server in Pune. A flood damages the server room. Under…
Accounts and Records; E-way Bill in other exams
The same ground in other exams, if you are preparing for more than one or want another angle on it.
Accounts and Records; E-way Bill: frequently asked questions
How long must GST accounts and records be kept?
Under Section 36 of the CGST Act, generally for 72 months from the due date of furnishing the annual return for the year to which the records relate. If the person is a party to an appeal, revision or any other proceedings, or an investigation is pending, the records must be kept for one year after the final disposal of such proceedings, or for the 72 months, whichever is later.
What is the difference between Part A and Part B of an e-way bill?
Part A contains the consignment and invoice details, such as the GSTIN, place of delivery, invoice number and date, value, HSN code and reason for transport. Part B contains the vehicle details. Part B is updated when the vehicle or mode of transport changes.
How do I calculate e-way bill validity?
For regular cargo, the bill is valid for one day for every 100 km or part thereof. For over-dimensional cargo, it is one day for every 20 km or part thereof. Validity can be extended in the prescribed circumstances, within a window of eight hours before or after expiry. Check the latest official text for the current conditions.
Can I cancel an e-way bill after the goods are intercepted?
No, an e-way bill cannot be cancelled once the goods have been verified in transit. Otherwise, it can be cancelled within 24 hours of generation if the goods are not transported or are not moved as per the details.
How should I answer e-way bill penalty questions in the exam?
Cite Section 129 of the CGST Act, which covers detention of goods in transit or in storage without proper documents. Apply it to the case facts such as the missing e-way bill or wrong details. For taxable goods, the penalty is 200% of the tax payable if the owner comes forward, or 50% of the value of goods reduced by the tax amount paid on them if the owner does not come forward. For exempt goods, it is 2% of the value or ₹25,000, whichever is less, if the owner comes forward, and 5% of the value or ₹25,000, whichever is less, if the owner does not.