Short answer: Under section 35(2) of India’s Central Goods and Services Tax (CGST) Act, every transporter must keep records identifying the consignor, consignee and relevant goods details, whether or not the transporter is GST-registered. The operating file should show what was transported, delivered and, where applicable, stored in transit, with records maintained for each branch.
Those records support the movement trail, but they are not normally the document that creates a buyer’s input tax credit (ITC) entitlement. A registered recipient generally needs the eligible tax document—usually a compliant supplier tax invoice—and must connect it to the purchase, receipt and transport evidence. An e-way bill or transporter register alone does not prove that every ITC condition has been met.
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Transporter and recipient duties are different
GST recordkeeping becomes clearer when the two roles are separated. The transporter documents the physical movement and custody of goods. The registered recipient documents the taxable purchase and establishes its own ITC eligibility.
| Question | Transporter or carrier | Registered recipient claiming ITC |
|---|---|---|
| Whose legal duty is it? | Every transporter, registered or unregistered, must keep prescribed goods and party details. Carriers and clearing or forwarding agents handling goods for a registered person also have record duties. | The recipient must retain the eligible tax document and evidence that the purchase, receipt, use and other statutory conditions support credit. |
| What is the central file? | A branch-level shipment file covering consignor, consignee, goods, transport, delivery and storage in transit. | An invoice or other eligible document reconciled to the purchase entry, receipt record, e-way bill and payment or accounting trail where relevant. |
| What does the file prove? | What goods moved, between which parties, by which conveyance and what happened during transit. | That an eligible taxable supply was received for permitted business use and that the recipient satisfies the applicable ITC requirements. |
| Does it automatically establish ITC? | No. Transport records corroborate movement but do not replace the recipient’s tax document. | No single record is enough by itself; the invoice, receipt, reporting and other legal conditions must align. |
This division prevents a common error: treating a transporter’s records as if they were the recipient’s claim document.
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The statutory basis for a transporter’s records
Section 35(2) of the CGST Act applies “irrespective of whether he is a registered person or not.” The provision states: Every owner or operator of warehouse or godown or any other place used for storage of goods and every transporter, irrespective of whether he is a registered person or not, shall maintain records of the consigner, consignee and other relevant details of the goods in such manner as may be prescribed.
In ordinary business language, this means an unregistered road carrier is not outside the recordkeeping rule. Registration status changes how the transporter handles tax and invoices; it does not remove the basic duty to identify the parties and goods.
The CGST rules describe the operating scope more specifically. Records should cover goods transported, goods delivered and goods stored in transit. They are to be maintained for each branch. If a carrier or clearing and forwarding agent handles goods for a registered person, it must keep true and correct details of those goods and produce them when required by the authorities.
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What the transporter’s shipment file should contain
The law does not prescribe one universal spreadsheet, paper register or software product. Build a file that allows an officer or auditor to follow one consignment from booking through delivery, including any interruption or storage.
Identify the parties
- Record the consignor’s legal name and the consignee’s legal name.
- Capture the relevant addresses, GSTINs where provided, contact or booking references, and the branch responsible for the movement.
- For a carrier acting for a registered person, retain the customer’s instruction or consignment reference so the goods can be tied back to the contracting party.
Describe the goods
- Enter a practical description of the goods, package or unit count, and any identifying marks or numbers used in the transport documents.
- Record the weight or quantity used for the consignment. Where the movement is handled by a GTA, gross consignment weight is a required invoice particular.
- Keep the source document used to describe the goods—such as the tax invoice, bill of supply or delivery challan—rather than retyping information without a traceable reference.
Show the movement lifecycle
- Record the origin and destination, booking or pickup details, dispatch date, delivery date and proof of delivery.
- Note the vehicle or goods-carriage registration number and the transporter or subcontractor handling each leg.
- Document any storage in transit, including the place, dates, reason and release to the next leg.
- When goods move between conveyances, preserve the old and new conveyance references and the new e-way bill number generated before further movement.
Maintain branch-level traceability
Keep records organized by the branch that booked, held or delivered the goods. A central system can be used, but it should identify the responsible branch and preserve the original branch-level entries. If records are moved to a central archive, retain the index that maps the shipment to its branch, document number and storage location.
How transport records support an ITC file
Input tax credit is based on the recipient meeting the statutory conditions and holding an eligible document. The documentary list includes a supplier invoice complying with section 31, a debit note, a bill of entry and other prescribed documents. The recipient should reconcile that document to the actual purchase and receipt of goods.
A useful reconciliation connects four references:
- Tax document: invoice, debit note, bill of entry or other eligible document held by the recipient.
- Accounting entry: the purchase or inventory record showing what was booked and for which business unit.
- Movement evidence: transporter consignment record, delivery proof, vehicle details and the applicable e-way bill number.
- Receipt and use: goods-receipt note, warehouse entry or equivalent evidence that the goods arrived and were received for eligible business activity.
The transport evidence strengthens the audit trail by corroborating quantity, route and delivery. It does not replace the supplier’s compliant tax invoice, and it does not by itself establish registration, eligible business use, reporting, payment or any other ITC requirement applicable to the recipient.
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GTA invoice particulars to capture
When the transporter is a Goods Transport Agency (GTA), its invoice needs shipment-specific information in addition to the ordinary prescribed invoice particulars. Keep the following together for each consignment:
| Particular | What to record | Why it matters |
|---|---|---|
| Gross consignment weight | The gross weight stated for the consignment. | Links the invoice to the physical shipment and freight charge. |
| Consignor and consignee | Names of the party handing over the goods and the party receiving them. | Identifies the supply participants and the movement endpoints. |
| Goods-carriage registration | The registration number of the vehicle or goods carriage. | Connects the invoice with the conveyance used. |
| Goods details | Description and other prescribed identifying information. | Allows the consignment to be matched to the source document. |
| Origin and destination | Place from which the goods were collected and place to which they were sent. | Shows the contracted route and supports delivery verification. |
| GSTIN of the person liable to pay tax | GSTIN of the consignor, consignee or GTA, as applicable to the transaction. | Identifies the person responsible for the tax treatment. |
| Other prescribed invoice information | Complete the remaining particulars required under the invoice rules. | Prevents a shipment-specific invoice from being treated as complete when it is not. |
Do not assume that a transport document with a vehicle number and route is a substitute for a GTA invoice containing the required particulars.
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Linking e-way bills to the record trail
E-way bill requirements can change through amendments, notifications and state or territory-specific measures. Use the current consolidated rules for the movement in question. The operational links below are the recordkeeping points that should be preserved:
- Start with the source document. Keep the invoice, bill of supply or delivery challan information used to create the movement record.
- Store the e-way bill number with the shipment ID. The transporter’s register, dispatch record and recipient’s purchase file should point to the same number where the e-way bill is applicable.
- Record the conveyance. Preserve the vehicle registration and the date or leg for which it was used.
- Handle a conveyance change before movement continues. If the goods transfer to another conveyance, generate a new e-way bill before further movement and retain both the original and replacement references.
- Handle consolidated movements. When multiple consignments travel in one conveyance, the transporter generates the applicable consolidated e-way bill and keeps its number linked to each underlying consignment.
- Generate when the consignor has not done so, where the rule requires. If the consignor has not generated the e-way bill and the applicable value condition is met, the transporter uses the invoice, bill of supply or delivery challan details to generate it.
These steps describe document linkage, not a universal threshold or exemption. Confirm the current trigger, form, exception and validity rules before relying on an e-way bill procedure.
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How long to retain GST transport records
Section 36 of the CGST Act sets the ordinary period at 72 months from the due date for furnishing the annual return for the year to which the records relate. The starting point is therefore not simply 72 months from the invoice date or delivery date.
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For example, determine the financial year to which a shipment record belongs, identify the due date for that year’s annual return, and count 72 months from that due date. Apply the same logic consistently to the transporter’s register, source documents and linked delivery records.
A longer period applies when the records are connected with an appeal, revision, another proceeding or an investigation for an offence. Keep the subject-matter records until one year after final disposal or until the ordinary 72-month period ends, whichever is later. Place a hold on deletion as soon as a notice, investigation or proceeding identifies the relevant transactions.
Electronic storage and audit readiness
Electronic records are permitted, but an electronic file is useful only if it can be restored, read and authenticated. The rules require a proper backup capable of restoration within a reasonable period after accidental or natural destruction.
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- Keep an indexed shipment identifier that links the booking, source document, e-way bill, vehicle leg, delivery proof and invoice.
- Back up the data and test restoration periodically; a backup that cannot be opened is not a dependable record.
- Preserve an audit trail showing additions, changes, cancellations and the user or process responsible.
- Retain source documents and the interlinkage between source documents, financial accounts and movement records.
- Document the record layout, data dictionary and explanations of internal codes so an outside reviewer can interpret the file.
- Keep sample copies or readable reproductions of the documents represented in the system.
When demanded, a registered person must be able to produce authenticated records in hard copy or readable electronic form and provide the audit-trail and interlinkage information. A transporter should maintain the same practical capability for records it is required to keep, even where a particular demand is addressed to another party.
Quick Recap
A practical monthly control routine
- Open the shipment record: assign one reference and enter consignor, consignee, goods, origin, destination and responsible branch.
- Attach the source document: save the invoice, bill of supply or delivery challan reference and the applicable e-way bill number.
- Update each leg: enter conveyance registrations, transfers, storage in transit and subcontractors as they occur.
- Close on delivery: attach proof of delivery, record shortages or exceptions and mark the final delivery date.
- Reconcile: compare the transporter’s file with the customer’s invoice and the recipient’s goods-receipt or accounting record when the service agreement requires it.
- Archive under the correct year: calculate the 72-month period from the annual-return due date and apply any proceeding-related hold.
- Test retrieval: select sample shipment numbers and confirm that an authorized user can produce a readable, complete file quickly.
Common failures and corrective actions
- Only an e-way bill is retained: add the underlying invoice, bill of supply or delivery challan and delivery evidence.
- The register lists a vehicle but not the parties: add consignor and consignee identities and the branch responsible for the movement.
- Storage in transit is invisible: record the storage location, dates and release to the next carrier.
- A vehicle change has no new movement reference: generate and link the required new e-way bill before movement resumes.
- Records are deleted 72 months after invoicing: recalculate from the annual-return due date and check for proceedings or investigation holds.
- Electronic data cannot be interpreted: preserve the layout, data dictionary, code explanations, source documents and audit trail, and test restoration.
- The buyer treats the transporter’s register as ITC proof: retain the recipient’s own eligible tax document and reconcile it with receipt, accounting and movement evidence.
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