50 Practical issues & possible solutions on E-way bills under GST


The free movement of goods across India without any checkposts in between is one of the major objectives of GST. Nation-wide E-Way bill system under GST is set to be implemented from February 1, 2018. Since E-way bill is one of the major reform in GST regime and would bring about a revolutionary change in the way movement of goods will be governed in the country. Further, a very short span of time is available for businesses to understand the intricacies of this new way bill system, resolve the entity-specific issues and streamline the systems and processes to align as per the requirement of the law. In wake of this need, this article intends to highlight and provide a possible solution for various practical challenges and issues that businesses may face in the era of e-way bills under GST  

Q.1 Where multiple invoices are generated on the same customer to be supplied through a same truck. Whether multiple E-way bills must be generated or one e-way bill shall suffice?

Ans: Each invoice/delivery challan shall be considered as one consignment and therefore for each invoice one e-way bill has to be generated irrespective of same or different consignors or consignees.

Q.2 Can multiple invoices be clubbed to generate one e-way bill?

Ans: No, Multiple invoices/delivery challan cannot be clubbed to generate one e-way bill. As provided above each invoice shall be considered as one consignment for the purpose of generating e-way bills. However, after generating all these EWBs, one Consolidated EWB may be prepared by transporter for transportation purpose, if all such goods are going in one vehicle.

Q.3 If goods are supplied in same truck, whether e-way bill would have to be generated even if value of each invoice individually is less than the threshold limit of Rs.50,000/- but overall it crosses Rs.50,000/-?

Ans: Sub Rule (1) of Rule 138 of the CGST Rules require that every registered person who causes movement of goods of consignment value exceeding fifty thousand Rupees is required to generate E-Way bill. Hence, as per this rule, the e-way bill may not be required to be generated if the value of consignment is less than Rs. 50,000/-

Further, sub-rule 7 provides that where consignor or consignee has not generated E-way bill in accordance with provisions of sub-rule (1) and the value of goods carried in the conveyance is more than Rs. 50,000 Thousand Rupees, the transporter shall generate E-Way bill based on the invoice/delivery challan/bill of supply. A plain reading of this sub-rule gives an indication that the E-Way bill is required in case value of consignment in the conveyance exceeds Rs. 50000, even though individual values may be less than Rs. 50,000/-.

However, if one carefully analyse sub-rule 7, it gets attracted only when a consignor/consignee who was required to generate the E-way bill having a value of consignment exceeding Rs. 50,000/- but has not generated (fails to generate) the same. If this view is taken, the e-way bill may not be required for consignment value less than Rs. 50,000/- even if the total value of goods in the conveyance exceeds Rs. 50,000/-.

e.g. if there are 51 consignments of Rs. 1,000 each by different consignors in a truck, the value of all individual consignments is less than Rs. 50,000/- then as per Sub Rule (1) – there is no need to generate E-way bill. If sub-rule 7 is interpreted in such manner that total value of all consignments to be considered, then transporter has to generate the e-way bill for all consignments (of the very small value of Rs. 1,000 each) which may not be the intention of the legislator. It is expected that suitable clarification will be issued by the government to clarify the same to ensure consistent practice across the country.

Q.4 How to generate the e-way bill, if the goods of one invoice are being moved in multiple vehicles simultaneously?

Ans: Where goods pertaining to one invoice are transported in multiple vehicles. For example, Goods transported in semi-knocked down or completely knocked down condition, the e-way bill shall be generated for each of such vehicles based on the delivery challans issued for that portion of the consignment and:

a) the supplier shall issue the complete invoice before dispatch of the first consignment;

b) the supplier shall issue a delivery challan for each of the subsequent consignments, giving reference to the invoice;

c) each consignment shall be accompanied by copies of the corresponding delivery challan along with a duly certified copy of the invoice; and

d) the original copy of the invoice shall be sent along with the last consignment.

Above methodology could be applicable in case of imports also where goods imported in the large container is transported through multiple trucks from the port to the factory.

Q.5 Whether E-way bills are required to be generated for movement of goods billed as services such as works contract, the composite supply of service, job-work charges etc.

Ans: Yes, an e-way bill is required to be generated in relation to supply and even for the purpose other than supply, therefore wherever there is any movement of goods of the consignment value exceeding Rs.50,000/- even as a part of services, the e-way bill would be required to be generated. In case, invoicing is later done as services, then the movement of such goods can take place under the cover of the delivery challan.

Q.6 How to determine the consignment value and Rs.50,000/- benchmark in case of goods removed other than that of supply i.e. sample issues, removal for trial, warranty removals, intra-state stock transfers etc.?

Ans: The term “Consignment Value” is neither defined under this law nor in e-way bill rules. However, where goods are transported for the purpose other than supply, where the invoice cannot be issued, the e-way bill can be raised against any other document like delivery challan, bill of supply etc. The value of such goods may have to be determined as per valuation provisions under GST.

Q.7 Is e-way bills system applicable even for movement of goods as a courier?

Ans: Yes, for the purpose of movement of goods, courier agencies may be regarded as the transporter of the goods. Therefore, an e-way bill would be applicable even for movement of goods as courier provided consignment value exceeds Rs. 50,000/-. There could be different business practices followed in case of courier industries which needs to be suitably considered for generating an e-way bill.

Q.8 In case of multimodal transport, where for first mile it is required to generate an e-way bill for road, second, mile by train and last mile by road. These transporters could be same service providers or different service providers. How to generate an e-way bill in this situation?

Ans: Where the e-way bill is generated and goods are to be transported from one conveyance to the other in course of transit, the transporter causing further movement of goods shall be required to update its details in Part – B of the e-way bill before the movement of such goods commences. Therefore, even in case of multi-modal transport initially, e-way bill must be generated giving the details of the vehicle carrying the goods by road. Once the goods are unloaded from this vehicle and loaded in the train, part B of E-way bill needs to be updated. Upon final transit of goods from rail to truck at last mile, part B must be further updated with the details of the vehicle carrying the goods for final delivery.

Q.9 How shall one calculate the distance and validity of goods in case of supply through multi-modal transport?

Ans: The distance and the validity of e-Way Bill shall remain the same even if the goods are supplied through a multi-modal transport. In order to calculate the validity of the e-way bill, the distance to be covered by all the modes combined together must be taken into consideration. The validity provided in the rules is as under:

Distance Validity
For a distance up to 100km One day
For every 100km or part thereof thereafter One additional day

Q.10 Who is cast with the ultimate responsibility of generating e-way bills? Consignor, consignee or the transporter?

Ans: The responsibility is cast on the registered person who causes the movement of goods. Hence, primary liability to raise E-way bill is on consignor. However, if consignor fails to generate the e-way bill, it may be generated by transporter also.

In case of supply of goods by an unregistered person to registered person, the liability to generate eway bill is on the recipient.

Q.11 How to generate the e-way bill in case goods are to be moved to a weighbridge situated outside the factory and invoice cannot be issued unless goods are weighed?

Ans: E-way bill is required to be generated for any movement of goods. In this situation, a factory may send the goods to weighbridge by raising delivery challan on self and the e-way bill needs to be generated for such movement. Once the movement is terminated and goods are received back in the factory, then invoice can be raised and another e-way bill needs to be generated for movement of goods for sale to the customer. Considering practical difficulties, the government should consider giving relaxation in such cases.   

Q.12 Whether an e-way bill is required to be generated for movement of goods from one unit of the company to another unit through own vehicle located within 10 km?

Ans: Yes, e-way bill is required to be generated even in case of movement of goods within 10 km. The relaxation updating part B (vehicle details) is given only in cases of movement of goods from the place of business of consignor to the business of transporter for further movement of such goods, Therefore, in all other cases, e-way bill needs to be generated even if the distance to be covered is less than 10 km.

Q.13 What is meaning of the term consignment value to determine the threshold of Rs.50,000/- and whether the same needs to be computed with taxes or without taxes?

Ans: The term “consignment value” is neither defined in the GST act nor in the e-way bill rules provided therein. However, since it is specifically provided in the FAQ issued by department that one invoice shall be considered as one consignment, therefore taking this analogy one can state that the value provided in one invoice shall be considered as the consignment value. Further, this value must be computed inclusive of taxes in order to determine the threshold of Rs.50,000/- for generation of the e-way bill.

Q.14 Whether E-way bill is required to be generated for movement of exempted goods also?

Ans: There is no provision in the E-way bill rule which provides that it is not required to be generated in case of goods exempted from levy of GST. Hence, it has to be generated in movement of all goods. However, Annexure to Rule 138 covers 154 items. If the goods covered under consignment fall within the list of these 154 items, there is no need to generate e-way bills.

Q.15 What if the same invoice contains both categories of goods i.e. ones exempted for the purpose of e-way bills and taxable, then whether e-way bill needs to be generated?

Ans: In relation to this query, we may refer to the Rule 138 of CGST Act which provides that:

  • Every registered person who causes movement of goods of consignment value exceeding fifty thousand rupees shall before commencement of movement of goods raise an e-way bill.
  • Further, it is provided that a person is not required to generate an e-way bill if such movement is in regards to the goods specified in the Annexure to this Rule.

In view of the above, if the invoice covers the consignment which is not covered under list of 154 items, E-way has to be generated.

Q.16 How e-way bill needs to be generated in case of supply of goods by an unregistered person to a registered person?

Ans: Where the supply of goods is made by an unregistered person to a registered person, the e-way bill shall be generated by the recipient of such goods, as for the purpose of supply he can be said to be the person causing the movement of goods. Therefore, recipient, in this case, would generate e-way bill by furnishing details in Part-A of FORM GST EWB – 01.

Q.17 Can information submit for e-way bill be directly pushed for filing GST Returns?

Ans: The information furnished in the e-way bill will be available to the registered supplier on the common portal who may utilize the same for furnishing details in GSTR-1. The purpose is to facilitate the suppliers so that once information is furnished in the E-Way bill format, this is available to him for use in filing GSTR-1.

Q.18 What has to be done to the e-way bill, if the vehicle breaks down?

Ans: If the vehicle breaks down while in transit when the goods are being carried with e-way bill, then the transporter can cause to repair the vehicle and continue the journey. Where the goods are shifted to different vehicle, then the details of new vehicle must be updated in Part B and of e-way bill and continue the journey with new vehicle.

Q.19 How many times can Part-B or Vehicle number be updated for an e-way bill?

Ans: The user can update Part-B (Vehicle details) for each change in the vehicle used in the course of movement of consignment up to the destination point. However, the updating should be done within overall validity period of E-way bill.

Q.20 What has to be done, if the vehicle number has to be changed for the consolidated e-way bill?

Ans: There is an option available under the ‘Consolidated EWB’ menu as ‘regenerate CEWB’. This option allows changing the vehicle number to existing Consolidated EWB, without changing the EWBs and generates the new CEWB, which has to be carried with new vehicle. Old will become invalid for use.

Q.21 Can the ‘consolidated e-way bill’ (CEWB) have the goods / e-way bills which are going to be delivered before reaching the defined destination defined for CEWB?

Ans: Yes, the consolidated e-way bill can have the goods or e-way bills which will be delivered on the way of the consolidated e-way bill destination. That is, if the CEWB is generated with 10 EWBs to move to destination X, then on the way the transporter can deliver 3 consignments concerned to 3 EWBs out of these 10 and move with remaining 7 to the destination X.

Q.22 For the purpose of calculation of distance and validity, does it needs to be checked from the date and time of generation of individual e-way bill or whether the same needs to be calculated from the time of generation of consolidated e-way bill?

Ans: Consolidated e-way bill is like a trip sheet and it contains details of different e-way bill which are moving towards one direction, and these e-way bills will have different validity periods. Hence, consolidated e-way bill is not having any independent validity period. However, individual e-way bills in the consolidated e-way bill should reach the destination as per its validity period.

It is also worth noting that the date of invoice/delivery challan is not relevant for determining the beginning time of E-way bill.

Q.23 How does transporter come to know that particular e-way bill is assigned to him?

Ans: The transporter comes to know the EWBs assigned to him by the taxpayers for transportation, in one of the following ways:

  • The transporter can go to reports section and select ‘EWB assigned to me for trans’ and see the list.
  • The transporter can go to ‘Update Vehicle No’ and select ‘Generator GSTIN’ option and enter taxpayer GSTIN, who has assigned or likely to assign the EWBs to him.
  • The taxpayer can contact and inform the transporter that the particular EWB is assigned to him.

Q.24 Can Part-B entry be assigned to another transporter by authorized transporter?

Ans: Part-B can be entered by the transporter assigned in the EWB or generator himself. But the assigned transporter cannot re-assign to some other transporter to update Part-B on the EWB system. Hence, where goods are shifted in the course of movement from one vehicle to another vehicle, part B may be updated by the first transporter only not by subsequent transporters. This could create practical difficulties when multiple vehicles are used in the course of completion of movement.

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Q.25 It may be possible that the authorized transporter is getting the goods transported through another transporter who has given the vehicle on hire basis. Can Part-B be updated by such other transporter who is merely plying the vehicle on hire basis?

Ans: No, Part-B can be entered only by the transporter assigned to the e-way bills or generator himself. But the authorized transporter cannot re-assign the right to update the e-way bill to some other transporter to update Part-B. Therefore, in practical circumstances, it is the transporter who issues the consignment note would be the one who shall be issuing the e-way bill.

Q.26 In case any information is wrongly submitted in e-way bill. Can the e-way bill be modified or edited?

Ans: The e-way bill once generated cannot be edited or modified. Only Part-B can be updated to it. Further, even if Part A is wrongly entered and submitted, even then the same cannot be later edited. In such a situation, e-way bill generated with wrong information has to be cancelled and generated afresh again. The cancellation is required to be done within twenty-four hours from the time of generation.

Q.27 Can the e-way bill be deleted?

Ans: The e-way bill once generated cannot be deleted. However, it can be cancelled by the generator within 24 hours of generation. If it has been verified by any proper officer within 24 hours, then it cannot be cancelled. Further, e-way bill can be cancelled if either goods are not transported or are not transported as per the details furnished in the e-way bill.

A recipient has right to cancel the e-way bill within 72 hours of its generation.

Q.28 Form for filling Part A asks for transporter document number i.e. Railway receipt no or bill of lading etc. However, how one can enter these details before movement of goods as the same is available only after submitting goods to the concerned authority?

Ans: E-way bill has to be updated with transport document details within one hour of submission and collection of transport document from rail/air/ship authority. Ideally, Part-B has to be updated before movement of goods from the place to submit. Although, this aspect is not provided in the law but the mechanism is provided in the FAQ issued by department dated 06.12.2017.

Q.29 Whether e-way bill needs to be generated for sales returns, rejection etc.?

Ans: Yes, e-way bill needs to be generated for any movement of goods. Therefore, even in case of sales returns, the e-way bill needs to be generated and in this situation, e-way bill needs to be generated by that person who is causing movement of such sales return or the transporter who is actually moving the goods.

Q.30 What should be done by the transporter if consignee refuses to take goods or rejects the goods for quality reason?

Ans: There is possibility that consignee or recipient may decline to take the delivery of consignment due to various reasons. Under such circumstance, the transporter can get one more e-way bill generated with the help of supplier or recipient by indicating supply as ‘Sales Return’ and with relevant document details, goods can be returned to supplier as per his agreement with him.

Q.31 What has to be done, if validity of the e-way bill expires?

Ans: The goods are required to be delivered within validity period of E-way bill. If validity of the e-way bill expires, the goods are not supposed to be moved. However, under circumstance of ‘exceptional nature’, the transporter may generate another e-way bill after updating details in Part B. Also, the Commissioner can extend the validity period of e-way bill for certain categories of goods as notified in the notification issued in this regard.

Q.32 How to enter invoice and who shall have to enter the details of e-way bills and how distance must be computed in case of “Bill to” and “Ship to” transaction?

Ans: If the addresses involved in ‘Bill to’ and ‘Ship to’ in an invoice/bill belongs to one legal name/taxpayer as per GSTIN within the state, then one e-way bill has to be generated. That is if the ‘Bill to’ is principal place of business and ‘Ship to’ is additional place of business of the GSTIN or vice versa in an invoice/bill, then one e-way bill is sufficient for the movement of goods.

If the addresses involved in ‘Bill to’ and ‘Ship to’ in an invoice/bill belongs to different legal names/taxpayers, then two e-way bills have to be generated. One e-way bill for the first invoice, second e-way bill is from ‘Bill to’ party to ‘Ship to’ party based on the invoice/bill of the ‘Bill to’ party. This is required to complete the cycle of transactions and taxes will change for inter-state transactions.

For example, A has issued invoice to B as ‘Bill to’ with C as ‘Ship to’. Legally, both B and C are different taxpayers. Now, A will generate one e-way bill and B will issue invoice and generate one more e-way bill. As goods are moving from A to C directly, the transporter will produce both the invoices and e-way bills to show the shortcut movement of goods.

This system would have a lot of practical challenges and implementation issues a lot of real-time coordination is sought prior to the movement of goods.

Q.33 How to handle the goods which move through multiple transhipment places?

Ans: Some of the consignments move from one place to another place till they reach their destinations. Under this circumstance, each time the consignment moves from one place to another, the transporter needs to enter the vehicle details using ‘Update Vehicle Number’ option, when he starts moving the goods from that place or the transporter can also generate ‘Consolidated EWB’ with the EWB of that consignment with other EWBs and move to the next place. This has to be done till the consignment reaches destination. But it should be within the validity period of EWB.

Q.34 What happens if the other party wrongly rejects the EWB after the goods have commenced movement. What is the recourse available to the supplier?

Ans: Where the other party wrongly rejects the e-way bill while the goods are in transit then such e-way bill will stand invalid. Presently, no mechanism is provided in the rules to deal with this situation. However, one of the options available to the supplier is to stop the vehicle once the e-way bill becomes invalid and then generate another e-way bill either himself or through transporter. Based on this new E-way bill, goods may be moved further. This issue if not addressed can cause unnecessary hardship even in genuine cases. Suitable clarification may be expected for the same.

Q.35 Whether e-way bill is required to be generated in case of goods imported on port of another State and customs cleared from there taken to own warehouse in home State?

Ans: Yes, In this case, the e-way bill will be generated by the recipient who is causing the movement of goods or by the transporter by furnishing the details in FORM GST EWB-01. For the purpose of furnishing the details of recipient, the same be selected as “Inward-Import” along with “Bill of entry” from an “Unregistered Person” as the supplier is located other country. “Foreign Country” should be selected in the drop-down menu of the State.

Q.36 Whether e-way bill is required to be generated to remove goods which are outside the scope of GST i.e. petrol, diesel, alcoholic liquor etc.?

Ans: Sub-rule (14) of Rule 138 of CGST Rules, 2017 provides that in case the movement is in relation to the goods specified under annexure, no e-way bill is required to be generated. However, the items like petrol, diesel, alcoholic liquor etc are not included under the annexure. Therefore, there could be a view that e-way may require being generated even though they are out of scope of GST.

However, there is another possible view that when goods are not covered within purview of GST law, rule issued cannot require carrying e-way bill for goods outside ambit of law as Rules cannot override the Act. Suitable clarification is required to be issued by Government for the same.

Q.37 Whether e-way bill would be required if transportation is done in one’s own vehicle?

Ans: Yes, e-way bill is required to be generated where the goods are transported by consignor or consignee in his own vehicle. In such case, the person causing the movement of goods may raise the e-way bill after furnishing the vehicle no. in Part B of FORM GST EWB – 01 if the value is more than Rs.50,000/-. Under this circumstance, the person can himself generate the e-way bill if registered in the portal as taxpayer. If the person is un-registered or end consumer, then need to get the e-way bill generated from the taxpayer or supplier based on the bill or invoice issued by him. Alternatively, he himself can enrol and log in as the citizen and generate the e-way bill.

Q.38 What happens if e-way bill is generated but no movement took place and if the e-way bill is not cancelled?

Ans: In case e-way bill is generated but no movement of goods took place, ideally in this scenario the e-way bill generated has to be cancelled. However, if the same is not cancelled within 24 hours, then the system would not allow the cancellation. In such a situation, one can request recipient to reject the e-way bill at his end in the common portal within 72 hours of its generation. However, if the time period for rejection of 72 hours also lapses then no mechanism is provided in the rules. Therefore, it is very important that all e-way bills that are not supported by proper movement of goods or are invalid or wrongly generated must be immediately cancelled.

Q.39 Many times goods are transported through a goods transport operators who will not be registered under GST, does not issue any consignment note and also do not issue any transport document or LR?

Ans: In respect of transport of goods by road, Transport Document is not mandatory field for the purpose of generation of E-Way Bill. A person may furnish other mandatory details like “Mode of transport”, “Transport ID” and “Vehicle No.” and can generate the e-Way Bill. Therefore, in case of transportation of goods through goods transport operator the person causing the movement of goods himself has to update Part A and also provide vehicle no. in part B and accordingly e-way bill needs to be generated. Also, if such operator takes registration and obtains TRAN ID, then e-way bill can be raised same as in case movement done through any other registered transporters.

Q.40 Is separate registration required for transporters and get transporter ID even though they are registered under GST and have a valid GSTIN. In other words, do all transporters need to get TRAN ID?

Ans: No, if a transporter is registered under GST and having a valid GSTIN then such transporter need not again obtain TRAN ID and instead his 15 digits GSTIN can itself be used as TRAN ID. However, an unregistered transporter needs to possess a valid TRAN ID in all cases. Unless the 15 digits transporter id is not entered, the transporter will not be assigned to the said e-way bill.

Q.41 How does the taxpayer become transporter in the e-way bill system?

Ans: Generally, registered GSTIN holder will be recorded as supplier or recipient and he will be allowed to work as supplier or recipient. If registered GSTIN holder is transporter, then he will be generating EWB on behalf of supplier or recipient. He needs to enter both supplier and recipient details, which is not allowed as a supplier or recipient.

To change his position from supplier or recipient to transporter, the taxpayer has to select the option ‘Register as Transporter’ under registration and update his profile. Once it is done with logout and re-login, the system changes taxpayer as transporter and allows him to enter both supplier and recipient as per invoice.

Q.42 How is the transporter identified or assigned the e-way bill by the taxpayer for transportation?

Ans: While generating e-way bill the taxpayer has a provision to enter the transporter id in the transportation details section. If he enters 15 digits transporter id provided by his transporter, the e-way bill will be assigned to that transporter. Subsequently, the transporter can log in and update the further transportation details to it.

Q.43 How does the taxpayer update his latest business name, address, mobile number or e-mail id in the e-way bill system?

Ans: EWB System (http://ewabill.nic.in) is dependent on GST Common portal (www.gst.gov.in) for taxpayers registration details like legal name/trade name, business addresses, mobile number and e-mail id. EWB System will not allow taxpayer to update these details directly. If taxpayer changes these details at GST Common portal, it will be updated in EWB system within a day. Otherwise, the taxpayer can update the same by selecting the option ‘Update My GSTIN’ and the details will be fetched from the GST common portal (www.gst.gov.in).

Q.44 What has to be entered in GSTIN column, if consignor or consignee is not having GSTIN?

Ans: If the consigner or consignee is unregistered taxpayer and not having GSTIN, then user has to enter ‘URP’ [Unregistered Person] in corresponding GSTIN column.

Q.45 What happens if the goods are detained unnecessarily without any proper reason?

Ans: If the goods or the vehicle of the taxpayer or transporter has been detained by the tax officers without proper reason for more than 30 minutes, then the transporter can generate “Report of Detention” in form GST EWB-04 giving details of office in-charge.

Q.46 If the goods are moving without e-way bill or partially declared, what are consequences if these are traced on the way to transportation?

Ans: The proper officer, as authorized by commissioner or any other person as empowered by him, has the power to make physical verification of conveyance and the e-way bill or e-way bill no. in case of all Inter or Intra-State movement of goods. Further, in case any goods are moving without e-way bill or where the details are partially declared, the proper officer has proper authority to detain or seize such conveyance or goods, and such shall be released after the payment of applicable tax or penalty as provided under section 129 of CGST Act, 2017.

Q.47 Whether Job worker will be liable to issue E-way bill along with goods sent after job work. Whereas job worker is sending goods along with his tax invoice of Jobwork charges only both in case of Inter-state and Intra-state.

Ans: Yes, Job worker will be liable to issue E-way Bill with respect to the goods sent after completion of his job work. Such goods have to be delivered on the basis of Delivery challan. These cannot be moved merely on the basis of job work invoice as such invoice covered only job work charges not the value of goods.

Q.48 If Jobworker is liable to issue E-way bill what value needs to be entered in Part-A, i.e. whether Job charges only or value of goods returned.

Ans: Job worker is required to raise an e-Way Bill on the basis of delivery challan and thus the value to be entered in Part-A shall be the value of goods returned and not the job work charges. However, he may send the invoice of job charges along with delivery challan and e-Way Bill. In our view, the value to be included in the E-way bill should be inclusive of the job work charges.

Q.49 If material movement having value more than Rs.50K has been done through public transport then whether E-way bill is required or not, if yes what details of vehicle to be updated in E-way bill.

Ans: When goods are transported by the consignor or consignee in conveyance of their own or a hired one (not by a transporter agent), such consignor or consignee shall be liable to furnish the details in Part B of FORM GST EWB – 01. Therefore, even if goods have been transported through a public transport, e-Way Bill is required to be issued.

Q.50 What treatment will be done for goods where transportation commenced prior to date of implementation of E-way bill but delivery completed to buyer after 01.02.2018.

Ans: E-way bill for the consignment value exceeding Rs. 50,000/- has to be generated before commencement of such movement. Hence, where movement of goods commenced before 1.2.2018, there may not be requirement of generation of E-way bill and one may continue the movement of goods without E-way bill. However, government has enabled the E-way portal on voluntary basis w.e.f. 15.1.2018. Hence, it is suggested to generate E-way bill voluntarily in such cases to avoid any problems in the course of transportation of goods.

Conclusion: E-way bill is new system designed and adapted from the similar schemes running in some States. There may arise many practical challenges in the beginning. We have made an attempt to address few practical issues which may arise in the course of implementation and generation of E-way bill. Wherever there is lack of clarity in the law/rules or portal, it is expected that the Government would come out with suitable clarifications so that the objective of the introduction of E-Way bill and the ultimate goal of “One Nation-One Tax” can be achieved and it does not cause an impediment in the ease of doing business. In case of difficulty writing to the GST Council is presently the best method of resolving issues.

Courtesy : CA Madhukar Hiregange from   www.hiregange.com

95 Replies to “50 Practical issues & possible solutions on E-way bills under GST”

  1. EXIM department says:

    we refer you answer to Q.4 How to generate the e-way bill, if the goods of one invoice are being moved in multiple vehicles simultaneously?

    in our case of imports our goods imported in the large container and is transported through same containers from the port to the factory.
    our problem is that our bill of entry has 5 containers in them.

    eway bill system allows one vehicle number / eway bill

    so how to we make the eway bill ???

  2. SAURAV AHUJA says:

    we carry a goods in our vehicle or in public transport goods (Two or three firm supply goods in same vehicle ) different customer or such common customer ( 35 customer )require eway bill or not ??

    if require how we can raise eway bill
    2 as in above , 35 customer have individually invoice amount not more 5k how we intitate w way invoice in consolidate way

  3. Mohd Farman says:

    Can we fill the E way bill of previous dated invoices

  4. rajkumar says:

    q. that seller party issued two invoices to sepretally both parties below amt. of Rs 50000/ i.e 37000/ and 37800/ and the same metarial load by one vehicle both party .so. what will be made e.way bill or combined bill

  5. Anonymous says:

    what happens if the eway bill date expires prior to the item reaching the client?

  6. Anonymous says:


  7. Imran khan says:

    E.g today is 25th may can i make eway bill for 17th may

  8. BM says:

    If the consignee is in the name of a department, is it possible to give the required document and id proof in the Institute’s name to which that department belongs. Please suggest.

  9. Avik manna says:

    I had one query. Suppose I raised two invoices for the same customer, one Invoice value is 56k while the other Invoice value is less than 50k. In such case should we generate two E-way bill for different invoices or only one Eway bill for the invoice value which is 50 or(>) .

  10. Mahesh Singh says:

    if i make a invoice in which inventory value is rs. 100000 and service charge is rs 10000 then how can i generate the eway bill for both inventory and service ?

    1. Anonymous says:

      Question: Where an invoice is in respect of both goods and services, whether the consignment value should be based on the invoice value (inclusive of value of services) or only on the value of goods. Further, whether HSN wise details of service is also required to be captured in Part A of the e-way bill in such case.

      Answer: Consignment value and HSN needs to be determined for goods only not for services as only the goods are in movement and e-way bill needs to be generated accordingly.

  11. ARUN KUMAR GUPTA says:

    Dear sir,
    we export goods to dubai under one invoice total cartoon 556 [ VEHICAL TOTAL 5]how we issue eway bill delhi to icd Patparganj Delhi goods dispatch through multi vehical.we are at Naraina our supplier diffrent place of delhi may we issue eway bill or our supplier billed us issue eway bill & goods deliver at icd delhi

  12. Suresh Shah says:

    Please help us in getting E-way bills in following 3 conditions,
    1) If we want to dispatch goods within the city for the value more than 50000 though a Taxi, how to generate e-bill Part-B, as there is no possibility of getting transporter ID & Transporter document number.
    2) If we dispatch materials though hand delivery,
    3) If client him-self takes delivery of materials in his own vehicle.

  13. Sandeep says:

    Q No. 49, pls inform what details of vehicle to be updated in E-way bill in case of public transport.

  14. Choudhary says:

    how to generate part B if goods movement thru E-Rikshaw and value exceed Rs 50k.

  15. Manabendra says:

    GST is ok but govt. is forcing small business people to depends on to much of rules & regulations & that too computer related works. Introducing e way bill for inside the state is one such. When there is no guarantee of power 24×7, net slow etc. How ssi can do a smooth business. Govt should not think just because net user is increasing, you make net dependent for everything. E way bill inside the state is a total foolish & it is a burden, increase cost & time. It is no way helpful to ssi n considered to be an adamant policy of govt

  16. RATAN says:

    What If we dispatch materials though hand delivery .

    1. Admin says:

      Only Motorized vehicle is required.

      1. RATAN says:

        What if I carry it in my car and personally deliver to the party.
        Secondly some time we send the material through office boy who goes by bus or train and hand delivers. How to generate way bill in such cases.
        Please clarify.Regards

  17. manish agarwal says:

    What is the necessity of generate e-way bill, if multiple invoices made for a customer on same day Above Rs. 50000/- and carried by a different vehicles in a part.
    Kindly Reply on it.

  18. Nimesh Joshi says:

    What if the eway bill server is down and the material to be shipped is of emergency service? Today I am facing the issue since last three hours. This is a government stock yard.

  19. Anonymous says:

    What if I have three firms with different GST numbers but goods movement occurs only when billing is done from third firm to party, but material invoice goes from first firm to second firm to third firm to party. Do I need to generate e way bill even for first firm to second firm and second firm to third firm even if there is no material movement.

  20. Sandeep says:

    Sir / Mam,

    if a E-Waybill prepared with a wrong (clerical error) truck no. and got caught by the sale tax authority, what are the clause on the same and how to get rid of the penalty since the Invoice No. / Value / Commodity is correctly mentioned only few digits of the Truck Number got wrongly entered and came to notice once the truck was en-route.

    Hope to get a answer with solution.

  21. Jain says:

    sir, we send material from mumbai to chennai before 30 days and same time we generated EWB. now material is at transporters godown bcz of some problem had with consignee so we not given instruction to transporter to release material. now we have to rebooked material from chennai (transporters godown) to Mumbai. now how to cancel old EWB?. and is now require new EWB from chennai to mumbai?. what should we do?… kindly update

  22. Kalu says:

    If vehicle nowrongly entered in consolidated ewaybill.then how much penalty will be paid by transporter

  23. kishor says:

    if consignor ans consignee both are same means ( stock transfer ) within state than how can i genrate the eway bill.

  24. arunkumar says:

    hello sir,

    for export invoice we are giving that sub type as export, but we are selecting as document type as tax invoice.

    for export there is no tax, if document type is tax invoice is it ok…

  25. Sharukh khan says:

    Q.31. part b is not entered by mistak…but parcel is gone on destination transport….
    Transporter is not giving parcel to customer..due to not entered of partb ….
    Now i can’t update eway bill because after 15 days we cant update part b………
    So can u please help me…wt to do now…

  26. Krishna says:

    Is hand written delivery challan is acceptable or not? Along with hand written delivery challan we are providing eway bill. Printed delivery challan details as per the accepted format we are making it. Some officers in our area says hand written DC’s not acceptable and asking for penalty. Kindly reply.

  27. Dharmendra Kumar pandey says:

    We imported Electronics items from Germany, we found some items are not functioning properly , now we are sending this to supplier (Germany) for repair & re import please provide the process to issue E way bill , can we select export or others?

  28. Vijayavelmurugan says:

    Dear Sir,
    I need to book the service material from Andra to Tamilnadu through professional courier.
    in this case what do we update the vechile number?
    Kindly reply

  29. P. Kotoky says:

    I have generated e way bill with wrong information and after 72 hours it came to my knowledge. The party rejected to receive the goods. What should I do.

  30. Gyandev says:

    Yes it can be done by issuing a delivery challan in current date referring bill no. generated in previous date. Invoice needs to attach along with DC

  31. Shivam Kedia says:

    When i am importing goods and directly i am selling to the buyer and the goods are not entering in my( importers) warehouse , in that case how many times do i require to generate an e way bill.




  33. mohit nangia says:

    i am a sound engineer. i provide sound system on rental basis. do i need to generatw e way bill too?? if yes then how?? coz sometimes i receive payments in cash asy parties dont have gst registered.. and for gst registered parties,, what is the method to make e way bills online?? NEED URGENT HELP…!!!!

  34. BANU says:


  35. vinod says:

    for an instance i have not generated waybill for a bill value of RS. 1 Lakh… The transportation of goods has taken place and there was no such checking during the transportation.

    In the above case what will be my liabiity..i.e., can the Gst officials penalise me at a later date for not generating waybill for the transaction.

  36. narendra says:

    what should i do if eway bill is expired and 24 hours has been passed to regenerate eway bill


    or an instance i have not generated waybill for a bill value of RS. 1 Lakh… The transportation of goods has taken place and there was no such checking during the transportation.

    In the above case what will be my liabiity..i.e., can the Gst officials penalise me at a later date for not generating waybill for the transaction.

  38. Karambir says:

    Eway bill is required if goods send on rent and rent value is less than 50000 , but value of goods is more. In case inter state supply. Please reply…..

  39. Breetha K says:

    While generation E-Way bill the below error has thrown.
    For Outward CKD/SKD/Lot supply type, Bill to state should be as other country, since the bill to GSTIN given is of SEZ unit.

    Please reply…….

  40. Kunal Deshmukh says:

    I have a question about EWay bill. I am the consignor. My customer is going to collect the material from my premises. Do I need to generate eway bill and if yes, How?

    1. Admin says:

      Only Motorized vehicles are supposed to issue e-way bills.

  41. ARUN GUPTA says:

    we are trader of iron and steel. we need to send the vehicle carrying goods to dharam kanta for weightment to know the quantity for which tax inovice and w e way bill is to be generated. Please let us know whether the delivery challan, issued for sending the vehicle to dharam kanta, is to be made in the name of dharam kanta or the in the name of the party whom the goods are sold.

    thanks and regards

  42. swati vira says:

    how to make a return eway bill for a catering done in another state? do i have a eway bill with zero value ? what sub section to select in supply inward section?? we have tables, cooking utensils to take back . also if am registered in delhi , i go to mumbai to do a catering , can i send my utensils from mumbai to jodhpur to do another catering ?can i do that on the invoice for jodhpur work or i need to show returning from mumbai and jodhpur invoice both?

  43. Saurabh D. Shah says:

    Recently the department has updated their website giving us the options to opt like “Bill to Ship to”, “Bill from Dispatch from” etc.

    I would like to ask my question by a practical example.

    I am buying goods from “A” from the state of Maharashtra. He is issuing me the eway bill and invoice to my company “B” with both buyer and consignee as “B” being registered in the state of Gujarat.

    The above goods are being sold by me to my customer “C” as buyer and “D” as his consignee both being different legal entities located in Rajasthan.

    Now the question is how many eway bills are required?

    Will my supplier from whom i am purchasing from Maharashtra will issue my the eway bill?

    Will my supplier need to mention my customer “C” as Consignee in their bill and eway bill? (Because if is to be done than my customer details will be exposed to my Supplier and solicitation process will start and i will keep loosing my customer)

  44. KAMLESH PATEL says:


  45. Prasenjit says:

    can we generate partly e-way bill against the same bill…??

  46. Pravi says:

    GST Query
    1 E Way bill raised
    2 wrong Invoice
    3. Goods supplied
    4 cannot cancel Eway bill as time is over.

    How to proceed?

  47. Mfhpl says:

    Only update material description correct and change after 72 hrs please gate me solution.

  48. mahesh says:


  49. sunil says:

    if material already deliver without e-way bill then after deliver we need to pass e-way bill

  50. Ankit jain says:

    I have generated eway bill as on 23 Nov 2018 of RS 7600000/- wrongly entered against the billing amount of RS 740000/- . I have received a msg on dt. 22.03.2019 from gst department that your e way bill and gst 3b return has a difference in tax amount above 100000/- so I check all bills and eway bill than I saw this mistake. What can I make this correct plz reply me fastly.

    1. Admin says:

      It is more likely that the SMS received to your from GST department asking you to verify tam amount above 1 lac is for your ITC not matching and not for E-way bill. In any case you can try to rectify the e-way bill mismatch also from e way bill portal.

    2. madhuri says:

      I m Also done this same mistake please inform what can i do now.

  51. pankaj bari says:

    If goods are demo purpose and send one place to other in this case e way bill is require or not

  52. Rasika says:

    If billing date is 30th March ’19 and dispatch will done on 2nd April ’19 , then Can we make E-way bill on 2nd April ’19 against 30th March invoice date.

  53. ALOK RASTOGI says:

    We are manufacturer of Machines & OEM, We have dispatched one machine, The machine is big in Size and cannot be accommodated in one Lorry, Hence this was loaded in 4 (Four) Separate Lorries.. We have raised Four Delivery Challan for all four Lorries for interstate movement. With (Four) E-Waybills with split value

    The GST Sachal Dal has detained last Lorry According to Them we have not mentioned Proportionate GST amount in E Way Bill Our Point is that GST Amount is mentioned in GST Invoice Since the machine cannot be loaded in One lorry , due to its size, we loaded it in Four Lorry with Delivery Challan,

    1. These Challan have mention of our GST Invoice, and also all 4 (four) challans have mention of our GST Invoice Number,
    2. The Identity & Value of the goods is established
    3. All Four Way Bill Numbers are mentioned on Invoice, & Each challan separately thus no clandestine removal of goods
    4. The Basic value is split in each challan is to cover the Insurance aspect, in case any shipment is damaged in transit

    You shall see that we have abide by E-Waybill Rules of CGST/SGST, there is no discrepancy
    Can the department issue notice under section 129 of CGST Act impose penalty, also how to release the shipment

  54. bharath says:

    if goods are going to replacement Eway bill required or not
    can any one rply me very urgent.

  55. Anonymous says:

    Sir, Is eway bill required when importer after paying igst at customs transported to party.

  56. Rajeev Thiruvoth says:

    What is to be done if courier service had delivered one parcel or carton box instead of 2 boxes as per Courier Docket for which ewaybill generated for the same invoice and DOCKET Number? .Nowadays we can not generate more than one ewaybill for one invoice. In that case what should be done for the partially delivered goods to reach at the destination?

  57. Avinash Patil says:

    Sir, Part material is already dispatched, now the rest of part material is dispatching against Delivery challan but we have raised the bill in the last month for full quantity, now how can i generate E way bill without mentioning the amount in the E way bill.

  58. murugadoss says:

    i am purchase other state Rs. 200000/- the party generate e way bill (with part B is not valid condition). the goods are arrived my local transport godwon. I am take the goods my own vehicle. This time want delivery challan or Not. (Transport godown to my place ). My doubt is necessary delivery challan or not necessary

  59. Praveen says:

    I would like to do a course on E way bill n it’s rules n clauses. Where in South Delhi can I attended these classes.

    1. Admin says:

      You can easily find helpful videos on youtube or you can search our video section for eway bill.

  60. Anonymous says:


  61. santosh says:

    what is the procedure if part-a of e way bill is Discarded and material not move

  62. KANNAN says:

    Once E-way Bill is Expired how to generate new E-way Bill for same Invoice. No.

  63. Srini says:

    How to cancel e-WAY Bill In case of Burnt Vehicle Validity got Expired & Extension also not possible

  64. shridhar says:


    I am a trader, purchased goods worth Rs.125000/-, lifted the goods from my suppliers warehouse and handed over to transporter(distance between warehouse and transport is 1 km) and prepared eway biil to my sales party. Is it necessary to prepare eway bill for transporting the goods from my suppliers warehoue to my transporter. please help me

  65. sumit kedia says:

    I have generated E-way Bill using GST hero App and now can’t able to cancel the same within 24 hours.

    Error: This e-way bill no Already Verified so You Can’t Cancel it Now..!!

    Any Solution???

  66. SUDHIR TANWAR says:

    goods delivered to port with e-way bill. Buyer rejected the goods after one month . What we have to do now.

  67. Neeraj Saraf says:

    I am from Mumbai and customer is also in Mumbai.
    I need to dispatch goods worth ₹3 lacs to customer but it is a new company and their GST registration is not received as yet.
    Can I dispatch the goods on Delivery Challan and issue the invoice after their GST registration certificate is generated??
    Furthermore, for generating Eway bill for delivery on challan, I have to select the option “Bill of supply”? And select URP under consignee name. Is that correct?

  68. vimal says:

    Yes if 1 days total supply excess/equal 50000 e way bill to be made.

  69. sunil trivedi says:

    sir,suppose we make 10 bills in day for single customer and value is going above 50k including all bills .is there necessary to be made eway bill? and we want to know if single bill is above Rs 50k and remaining bills are less than 50k in same day .in that case,is it compulsory to be made eway bills for all invoices which is above 50k and below 50k ?

  70. yuvi says:

    consignor is diffrent but consignee is same and the goods is more than 50000 then there is need of e way bill

  71. Deepak Vaikar says:

    We are selling goods with Ex-warehouse term. Dealer is lifting the goods from our warehouse. Who is responsible for generation of E-way bill. Whether Sender or Byers.

  72. premnarayan says:

    if in state invoice issued for receiver whose gstin same in one state invoice and supply at head office adress wrongly not write ship to when how much penalty may be imposed

  73. ramkumar m s says:

    Referring to situation stated in question No. 4,

    if the trucks are not cleared simultaneously, due to loading/ non reporting of truck in time,. but full consignment will be cleared on the same day.
    can we follow the same procedure

  74. VIKRAM KHOPKAR says:

    We are registered with GSTIN and we want to send material to NGO which is URP. They are carrying material in his own vehicle, please confirm In this case what Transporter ID i need to mention for genrate e-waybill.

  75. Shashikala says:

    I purchased mobile from online purchase on 17.03.2020 but mobile company generated bill in different name and address .Within 24 hours i communicated by mail the same problem and request them to change my name and address . but they are refused the same what is the solution , Is it possible them to correct GST bill and what is the procedure and Rule

    1. Admin says:

      Previously it was not possible to amend, but while filing current periods GSTR-1, one can do certain amendments of previous few months bills wrongly filed. How to do it is easily available in youtube videos. Hope it helps.

  76. Tejas says:

    Client want only 1 invoice of Whole Goods ordered
    We have 1 invoice of 8 lakh
    Part Delivery is ready and need to be delivered now which values to 3 lakh and Balance after a month
    So my question is whether we need to generate E way bill for the same bill 2 times??? 1st during the 1 part of delivery and Balance on deivery of Balance goods???

  77. RAHUL PARDESHI says:

    Generated e way bill did not cancel within the validity period and it got expired. Now should we generate a new e way bill or what to do please suggest?

  78. srinivas A says:

    we have generated a waybill on 30-7-2020,which was now noticed that the item rate was wrongly posted and the total amount varries about 50000=00 more than the supplied,.all the other perticulars remain same and the materials delivered at warehouse..how to correct it,already it was 10 days.

  79. syed badrudddin says:

    Dear all,
    we had generated e way bill on 01.09.2020 towards a material valued more than 50000 , as on that day the invoice no issued is canceled and material does not moved, we forget to cancel e way bill on 24 hrs and 72 hrs, now on 14.09.2020 we came to know that particular invoice is canceled but e way bill is not canceled , what to do? how it will effect my transaction while filling Gst returns, please any one can help me out.

  80. Anonymous says:

    i forgot to make an eway bill and it charged me a fine of 6,00,000 rs , why is such a big amount charged ?

  81. anand says:

    what if the receipent not filed gst returns then how to move the goods in emergency situation

  82. kinny says:

    If we want to dispatch goods within the city for the value more than 50000 and if f client him-self takes delivery of materials in his own vehicle.

  83. Geetha says:

    Can Transporter generate e-way bill instead of consignor. What to do if e way bill expired. Can Transporter extend the validity of the e-way bill. If we generate new e-way bill for invoice which we already generated way bill by using that invoice number we should pay tax for that also?

  84. Pulkit Madaan says:

    If I want to send goods where multiple transporters are required to reach the Consignee destination and due to some reason the 2nd transporter cannot ship the goods in the valid time limit provided by the gst portal…. And the eway has been expired…
    Please tell me how to go future in this situation…. Do we need to regenerate a new eway bill on behalf of the old eway bill or something else has to be done….

    1. R.P. JAIN says:

      If I want to send goods where multiple transporters are required to reach the Consignee destination and due to some reason the 2nd transporter cannot ship the goods in the valid time limit provided by the gst portal…. And the eway has been expired…
      Please tell me how to go future in this situation…. Do we need to regenerate a new eway bill on behalf of the old eway bill or something else has to be done….

  85. Brahmanand says:

    Dear All,
    We are sending goods from the office(Located in Bangalore) to our another branch in Mysore. In the bulk tool, i gave sub type as other & document type as Delivery challan.
    After, Uploading the Jason file the portal, getting an error like-Enter sub supply description for ‘Other’ Sub supply type.
    Since the issue arising or an error getting, am unable to generate an e way bill for Intra state supply or transfer. Pls guide me how to get resolve this issue, any other possibilities.
    Need yours guidance/ suggestion

  86. Brahmanand says:

    Hi All,
    We are sending goods from Bangalore to Mysore. In the bulk E way tool i gave sub type as “Other” & document type “Delivery challan”. After created a Jason & uploading the same in the portal, we are getting an error ‘Enter sub supply description for “Others” sub supply type.
    Since three days. We were getting this error & unable to generate a bulk e way bill.
    Need your suggestion, get the issue resolve. Pls suggest me

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