EWB requirement for construction services supplied alongwith material?

A practical question about GST invoicing and compliance for architects!

Invoicing Options: - *Separate Invoices*: You can raise separate invoices for the materials supplied and your architectural services.

This approach is recommended if you want to clearly distinguish between the supply of goods (materials) and services (architectural expertise). -

*Consolidated Invoice*: Alternatively, you can raise a consolidated invoice that includes both the materials supplied and your architectural services. This approach is suitable if you're providing a comprehensive package of goods and services.

GST Implications: - *GST Rates*: Ensure you're charging the correct GST rates for the materials supplied and your architectural services.

 The GST rate for architectural services is typically 18%. -

*HSN/SAC Codes*: Use the correct HSN (Harmonized System of Nomenclature) codes for the materials supplied and SAC (Service Accounting Code) codes for your architectural services.

 E-Way Bill (EWB) Requirements: - *EWB for Materials*: If you're raising a separate invoice for materials, you'll need to generate an EWB for the supplies.

The EWB will be linked to the invoice for the materials. -

 *No EWB for Services*: Since your architectural services are not subject to EWB requirements, you won't need to generate an EWB for the services portion.

Since you are providing both goods (materials) and services (architectural and construction services) under a single project, you need to determine whether this qualifies as a composite supply or a works contract under GST.

• Works Contract (Section 2(119) of CGST Act, 2017):

  • Since construction (immovable property) is involved, it is treated as a works contract, which is considered a supply of service under GST.

  • In this case, a single invoice should be issued for the entire contract value, including both materials and services.

  • The applicable GST rate would be as per works contract services (18%).

• Separate Invoices (Optional but Uncommon):

  • If you are only supplying materials separately, not as part of a works contract, you can raise two separate invoices—one for materials and another for services.

  • However, this could create ITC (Input Tax Credit) complications and is not recommended if the supply is a single contract for construction.

2. E-Way Bill Requirement

• If you raise a separate invoice for materials, you must generate an E-Way Bill (EWB) while transporting the materials to the construction site, provided:

  • The consignment value exceeds ₹50,000.

  • The material is being moved across states or within the same state (if EWB is applicable as per state rules).

• If you issue a single invoice for works contract, EWB is not required for the service component, but an EWB may be needed for material movement.

Conclusion

• Best Approach: Issue a single invoice under works contract service (SAC Code: 9954) for both materials and services at 18% GST.

• If issuing separate invoices:

  • Raise EWB for material supply if the invoice is separate and value exceeds the threshold.

  • The service component does not need an EWB.

Thank you both for the replies.

I am raising consolidated invoice marking as Construction & Architectural Services for XYZ Property and including the total amount of material + my expertise fee and 18% GST on the total.

Since it will be including both the aspects as it is provided as bundled service i don't think raising EWB shall be necessary.

Also, the project has been completed now and i am raising single invoice at the end, and for paperwork purpose i hold the purchase invoices on my GSTIN (also, taking its ITC) with 'shipping to' details for the site. so, i dont think i need to raise the EWB seprately.

I hope its the right way to do such and avoid complications.

Yes, You can go this way.