GST E-Way Bill Services
for Compliant Movement of Goods Under the CGST Act 2017

At N D Savla & Associates, our qualified Chartered Accountants help businesses set up and run their e-way bill compliance accurately, so that the movement of goods is documented in line with Section 68 of the CGST Act 2017 and Rule 138 of the CGST Rules 2017.

Most e-way bill issues arise from operational gaps rather than from the law itself — a wrong vehicle number, an expired validity, an unupdated Part B on transhipment, or a missed cancellation window. Therefore, our practice treats the e-way bill as an operational compliance that connects directly with the wider GST return filing cycle, GSTR-1 reporting, GST invoicing, and the broader indirect tax framework, so the movement records and the GST records match each other on every transaction.

The Statutory Basis Under Section 68 and Rule 138

The e-way bill is mandated by Section 68 of the CGST Act 2017 read with Rule 138 of the CGST Rules 2017. Therefore, every person in charge of a conveyance carrying any consignment of goods of value exceeding the prescribed amount is required to carry the e-way bill in addition to the invoice or other prescribed document. Hence, both the document and the discipline of carrying it are statutory.

When an E-Way Bill Is Required

An e-way bill is generally required where the value of the consignment exceeds the threshold prescribed by Rule 138 of the CGST Rules 2017, including the value of tax and excluding the value of exempt supplies in the same conveyance. Therefore, both inter-State and intra-State movements above that threshold attract the e-way bill requirement, subject to the State-specific notifications for intra-State movement. Hence, the threshold is the first check before any consignment leaves the premises.

The Two Parts: Part A and Part B

An e-way bill in Form GST EWB-01 has two parts. Part A captures the supplier and recipient GSTIN, the invoice or document details, the HSN, the value, and the place of dispatch and delivery. Part B captures the vehicle number and transporter details. Therefore, both parts must be filled in before the movement starts, except in limited cases where Part B can be updated separately. Hence, an e-way bill with Part A alone, where Part B is required, is not complete.

A GST e-way bill captures a defined set of details for the movement of goods. Therefore, the following list summarises what an e-way bill in Form GST EWB-01 must reflect.

An e-way bill is required in a defined set of situations under Rule 138 of the CGST Rules 2017. Therefore, knowing the trigger conditions and the exemptions is essential to running clean movement compliance.

Inter-State and Intra-State Movement Above the Threshold

An e-way bill is required for the inter-State movement of goods of a value exceeding the threshold prescribed by Rule 138, generally fifty thousand rupees per consignment. Therefore, the same rule applies to intra-State movement, subject to State-specific notifications which can fix different thresholds for movement within a State. Hence, the State of the movement matters for the threshold check, not just the GSTIN.

Movement for Reasons Other Than Supply

An e-way bill is also required where goods are moved for reasons other than a supply, such as job work, sales return, repair, or stock transfer. Therefore, the requirement is not limited to outward supplies. Our ITC-04 page covers job-work documentation in more depth.

Inward Supply From an Unregistered Person

Where a registered recipient receives goods from an unregistered supplier and the consignment crosses the threshold, the recipient is required to generate the e-way bill. Therefore, the responsibility to comply shifts to the recipient in this situation. Hence, purchases from unregistered suppliers attract a different operational discipline.

Rule 138 of the CGST Rules 2017 sets out who is responsible for generating the e-way bill. Therefore, the responsibility shifts depending on who is registered, who is moving the goods, and whether the transporter has been engaged.

Registered Supplier or Recipient

The primary responsibility is on the registered supplier or recipient causing the movement of goods. Therefore, the supplier of an outward supply typically generates the e-way bill, while the recipient generates it for an inward supply from an unregistered person. Hence, the GSTIN holding the supply position bears the operational duty.

The Transporter Where the Other Two Fail

Where neither the supplier nor the recipient generates the e-way bill, and the goods are handed over to a transporter, the transporter is required to generate it before the movement starts. Therefore, the transporter is the backstop in the chain. Hence, the engagement with transporters should include a clear responsibility statement on who generates the e-way bill on the consignment.

Consolidated and Multi-Vehicle Movements

Where a transporter is moving multiple consignments in a single vehicle, a consolidated e-way bill in Form GST EWB-02 can be generated. Therefore, the consolidated e-way bill captures all the individual e-way bills against one vehicle. Hence, transport operations are simplified for full-truck-load and part-truck-load shipments.

A GST e-way bill is not valid indefinitely. Therefore, the validity is tied directly to the distance the goods are to travel and to the time elapsed since generation.

Distance-Based Validity Under Rule 138(10)

For normal cargo, an e-way bill is valid for one day for every two hundred kilometres or part thereof. For Over-Dimensional Cargo, the validity is one day for every twenty kilometres or part thereof. Therefore, the validity is calculated from the time of generation by the system itself based on the distance entered. Hence, both the distance and the start time of movement must be accurate.

Extension and Cancellation Windows

Where movement is genuinely delayed, an e-way bill can be extended within eight hours before the expiry of its validity or within eight hours after the expiry, in Form GST EWB-05. Furthermore, an e-way bill can be cancelled within twenty-four hours of generation in Form GST EWB-06, if the consignment is not transported as detailed in the e-way bill. Therefore, both windows must be tracked actively by the supplier, the recipient, and the transporter.

Section 68 of the CGST Act 2017 requires the person in charge of the conveyance to carry the prescribed documents during the movement of goods. Therefore, the e-way bill is carried along with the tax invoice or bill of supply or delivery challan, and the e-way bill number is available for verification on the portal. Hence, a properly generated e-way bill is only useful if it is also physically or electronically present with the conveyance during the journey. Our GST invoicing page covers the invoicing side of these documents in more depth.

For taxpayers covered by the e-invoicing requirement, Part A of the e-way bill is auto-populated from the data of the e-invoice generated on the Invoice Registration Portal. Therefore, the e-invoice and the e-way bill are increasingly linked at the data level, which both reduces duplication and increases the importance of accurate e-invoice data. Hence, businesses on e-invoicing should treat the e-invoice as the upstream source of the e-way bill, not as a separate document.

Moving goods without a valid e-way bill is not a paperwork issue alone. Therefore, the consequences sit squarely under the CGST Act 2017 and can affect both the consignment and the conveyance.

Our practice covers every realistic e-way bill profile. Therefore, the approach is calibrated to the kind of movement and the workflow involved.

Our e-way bill practice spans every business profile that moves goods within India. Therefore, we tailor every engagement to the kind of movement and the volume.