GST FAQs: E-Way Bill, KCC Credit, and RWA Charges

In India, Goods and Services Tax (GST) compliance is frequently answered with questions from organisations, farmers, or people who belong to residential welfare associations. One of the most frequent questions relates to E-Way Bills, Kisan Credit Card (KCC) transactions, and whether GST applies to charges by Resident Welfare Associations (RWAs).

GST FAQ 1: What Is an E-Way Bill Under GST?

In the ordinary course of business, an e-way bill is an electronic document that must be obtained prior to shipping inventory worth at least ₹50,000 and this is a requirement under the GST regime. The e-way bill is produced online and is evidence that an inventory shipment is in accordance with the requirements of the GST. The principal goal of the e-way bill mechanism is to track the movement of products, as well as to guarantee compliance with tax regulations and to prohibit tax evasion in relation to the movement of products.

The following are key points regarding E-Way Bills:

Interstate transportation of goods is mandatory when the total value of the offers exceeds ₹50,000.

In addition to being necessary for transporting supplies, E-Way Bills will also be available for non-supply and/or inward supplies when they are received from an unregistered delivery service.

Suppliers, receivers, and freight forwarders can generate an E-Way Bill on the GST E-Way Bill website.

E-Way Bills must be carried as physical copies or electronic copies upon delivery.

E-Way Bills are valid for:

200 km or less = 1 day

Each additional 200 km or part of a kilometer from the place of origin is 1 additional day.

The 1 day validity of an E-Way Bill starts when the E-Way Bill is generated. Failure to generate, and carry an E-Way Bill can result in fines, goods and/or vehicles being detained or taken, and the businesses involved in the shipment may incur more costs than normal due to additional compliance with the GST laws.

GST FAQ 2: Is GST Applicable on KCC Credit Transactions?

Farmers are the target audience for the KCC scheme, which is designed to help them obtain affordable and timely credit for their farming needs (i.e., crop cultivation, etc.) by utilising Government backed products tailored specifically to their needs. Credit Provided to Farmers is Considered Above Mentioned Category of Tax Code As Per GST And Therefore No GST Will Apply:

Most importantly, since providing credit is considered an exempt supply (not subject to tax) under the Goods & Services Tax (GST) Act, all financial institutions that offer this type of product will not charge the recipient of this card.

For example, if farmers take out a loan from their bank, and that bank charges interest based on the rate it normally applies to all loans, that interest will not be subject to GST.

If the financial institution providing the loan assesses a one-time material processing fee associated with issuing the card, and that assessment does not relate specifically to the issuing of credit to the farmer under the KCC scheme, that fee will be treated as taxable under GST.

GST FAQ 3: Are RWA Charges Taxable Under GST?

RWAs, or Resident Welfare Associations, charge residents for common facilities and services like Security, Housekeeping/Lift Maintenance, Gardening, Water Supply and Electricity for Common Areas, and collect Maintenance Charges Monthly. For GST to be applicable to RWA Maintenance Charges, the following two conditions must both be met:

The following are key points regarding E-Way Bills:

Monthly Contribution per member is greater than ₹7,500

Annual Aggregate Turnover of the RWA is more than ₹20 Lakhs (for special category states it is ₹10 Lakhs)

If and only if both of the above conditions are not met, then GST will not be applicable to the Maintenance Charges collected by the RWA.

GST Rate on Maintenance Charges of RWAs.

Further, GST will apply at the rate of 18% on the Maintenance Charges, once the Monthly Contribution exceeds ₹7,500 per member, and will apply to the full amount of the Maintenance Charges, and not just to the excess amount.

Clarifications of Importance:

Contributions collected for Sinking Fund, Repair Fund or Common Amenities Fund will also be included in determining the ₹7,500 limit per Member.

Amounts collected by RWAs on behalf of Residents (such as Municipal Taxes and Water Charges charged as per actuals) are not included in the ₹7,500 limit provided that there are proper documents available to support this.

In addition, RWAs that are registered for GST are allowed to claim Input Tax Credit (ITC) on eligible expenses such as Security and Maintenance Services.

Refer here: GST on Housing Society Maintenance Charges in India

Input Tax Credit (ITC) for RWAs

Registered RWAs under the GST Act are allowed to take tax credit on costs incurred for items and services that are taxable, which are utilized by the members to provide tax-based maintenance services for their residents. Some typical examples of eligible costs include:

Security services, housecleaning and manpower supply.

Repair and maintenance of common areas (lifts, plumbing, electrical systems).

Utilities like electricity and water; and other utility services as long they qualify under GST rules

However, the only time an A/C may apply for ITC will be if the charge paid for providing the maintenance service is taxable. If a member’s monthly contributions are less than ₹7,500 per month and the service provided to them is exempt, then the A/c will have to reverse its ITC by the prescribed percentage.

Common Compliance Mistakes to Avoid

Not Generating E-Way Bills for Applicable Movement of Goods

Many business owners believe that E-Way Bills need to be generated only for sales. However, E-Way Bills also need to be generated for job work, branch transfer or return of goods if the value of the goods exceeds ₹50,000. If goods are not accompanied by an E-Way Bill, the goods will be detained and penalties may be levied against the person responsible for the transport of the goods.

Assuming All Charges Relating to KCC (Kisan Credit Card) are GST Exempt

Although the interest on KCC loans is not subject to GST, other charges such as processing fees, documentation, etc. that are in connection with KCC loans may be subject to GST. If all revenue related to KCC is treated as not subject to GST, the payer will be unable to pay the appropriate amount of GST on that income.

Charging GST on RWA (Resident Welfare Association) Maintenance Fees if Under ₹7,500

Most RWAs charge GST on a monthly maintenance fee of ₹7,500 per month or lower, even though GST only applies when the total monthly charge exceeds ₹7,500 and the total annual turnover from all sources exceeds ₹20,000,00.

GST Compliance Overview: E-Way Bill, KCC Credit & RWA Charges

Topic	Applicability Under GST	Key Threshold / Condition	GST Rate	Common Mistake
E-Way Bill	Mandatory for movement of goods	Consignment value exceeds ₹50,000	Not applicable	Not generating E-Way Bill for job work or branch transfers
E-Way Bill Validity	Depends on distance travelled	Up to 200 km – 1 day	Not applicable	Using expired E-Way Bill during transit
KCC Loan Interest	Exempt from GST	Credit provided for agricultural purposes	Nil	Treating all KCC-related charges as exempt
KCC Processing Charges	Taxable (if applicable)	Non-interest service charges	18%	Ignoring GST on documentation or service fees
RWA Maintenance Charges	Taxable only if conditions met	> ₹7,500 per member per month and turnover > ₹20 lakh	18%	Charging GST below ₹7,500
RWA Annual Turnover	Determines GST registration	Exceeds ₹20 lakh	Not applicable	Delaying GST registration
ITC for RWAs	Allowed with conditions	Only for taxable supplies	As applicable	Claiming ITC on exempt maintenance collections
Penalty for Non-Compliance	Applicable	E-Way Bill or GST violations	As per law	Assuming small errors won’t attract penalties

Conclusion

When you know the right thresholds and conditions of the GST system with regard to e-way bills, credit transactions via KCC, and maintenance charges from RWAs, your compliance with the GST provisions will be easy for you to understand. You can help prevent penalties from being imposed on you under the provisions of the GST Law by maintaining proper documentation, continually reviewing the GST system for its applicability, and ensuring that your documentation is within the limits required by the GST system.

Suggested Read: Know about GST on Freight Charges