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    Indirect Tax Alert

    E-Way Bill HSN Code Update and GST Portal Functionalities for GTA Taxpayers

    Recent system-level updates under the GST framework have direct compliance implications for both general taxpayers generating E-Way Bills and Goods Transport Agency (GTA) taxpayers using the GST portal for declaration-based options. These updates are operational in nature, but their impact is significant because they affect how taxpayers report transaction details, exercise tax payment options, and maintain continuity in GST compliance.

    Two important advisories merit close attention: the first relates to revised HSN code reporting requirements for E-Way Bills, and the second concerns the functionalities made available on the GST portal for GTA taxpayers. Both updates require process-level readiness rather than mere awareness.

    E-Way Bill Advisory: HSN Code Reporting Requirement

    As per the NIC advisory, effective 1 February 2024, taxpayers generating E-Way Bills are required to comply with revised HSN code reporting rules linked to their Aggregate Annual Turnover (AATO). Taxpayers with AATO above Rs. 5 crore must report at least a 6-digit HSN code for B2B and export transactions, while taxpayers with AATO up to Rs. 5 crore must report at least a 4-digit HSN code.

    This change is not merely technical. It affects ERP configurations, invoice-level data quality, and E-Way Bill generation workflows. Businesses that have not aligned their masters and transaction systems with the prescribed HSN format may face validation issues during E-Way Bill generation. For businesses managing multi-location dispatches or export transactions, this becomes part of broader GST advisory and compliance preparedness.

    The official advisory can be accessed here: EWB-HSN-Advisory.pdf

    GST Portal Functionalities for GTA Taxpayers

    The GST portal has also enabled specific functionalities for GTA taxpayers to streamline declaration-based compliance. These include online filing of Annexure V and Annexure VI for existing GTA taxpayers, online filing of Annexure V for newly registered GTA taxpayers, and the facility to upload manually filed Annexure V for FY 2023-24.

    These functionalities are important because the option exercised by a GTA for payment of GST under the forward charge mechanism is deemed to continue for subsequent financial years unless the taxpayer files Annexure VI to revert to the reverse charge mechanism. In other words, this is not a one-time procedural choice without future effect; it has continuity implications across years.

    Further, GSTN clarified that GTAs who filed the declaration for FY 2024-25 on the portal during the specified period from 27 July 2023 to 22 August 2023 would be treated as having filed a valid declaration, and such taxpayers need not refile Annexure V for subsequent years if they intend to continue under forward charge.

    The complete GST portal update can be accessed here: GST Portal Advisory for GTA Taxpayers

    Key Compliance Implications

    From a practical standpoint, these updates require taxpayers to focus on three areas:

    • reviewing HSN masters and transaction-level data for E-Way Bill readiness;
    • validating whether the correct forward charge or reverse charge position has been exercised for GTA services; and
    • maintaining proper documentation of declarations and portal-based submissions for future reference.

    For tax teams, the broader implication is that GST compliance is increasingly system-driven. Portal validations, master-data accuracy, and option-based filings are now as important as substantive tax positions. This is where businesses often benefit from a wider indirect tax advisory review, supported where needed by a structured GST health check and compliance review.

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