All You Need to Know about E-Way Bills under GST

All You Need to Know about E-Way Bills under GST


Definition & Scope: Under GST Rule 138, an e-way bill is an electronic document (Form GST EWB-01)
generated on the common portal before transporting goods. It must be carried by the person in charge of the conveyance when moving any consignment of goods of value exceeding ₹50,000 (e.g. invoice value including taxes) across or within states . The e-way bill system was introduced to digitally track goods movement, curb tax evasion and streamline logistics under GST . Under
Section 68(12) of the CGST Act, the person in charge of the conveyance must carry the e-way bill (in
physical or digital form) along with the invoice or delivery challan. An e-way bill generated under GST is valid nationwide .

Applicability Thresholds: By default, any registered person causing movement of goods (for supply,
or otherwise, or inward from an unregistered supplier) above ₹50,000 in consignment value must
generate an e-way bill . The ₹50,000 limit is per consignment (i.e. if multiple invoices are transported
together, their aggregate value applies). Certain states may notify higher intrastate thresholds (e.g.
some earlier relaxations raised it to ₹1 lakh intrastate), but as of 2024 all states have reverted to the
₹50,000 limit for GST purposes. For example, Rule 138(1) explicitly mandates e-way bills for any
consignment exceeding ₹50,000 . Note: some states (e.g. Gujarat, Tamil Nadu) had permitted intrastate movement up to ₹1 lakh without e-way, but no state currently mandates e-way bills above ₹50,000 (exceptions apply only to notified goods – see below).

Who Must Generate & When: The supplier or recipient (if registered) who causes the movement
must furnish Part A on the portal before movement. Part A includes document details (invoice/challan), consignor/consignee, value, HSN codes, reason for transport, etc. . If goods are handed to a transporter, the registered consignor/consignee must first fill Part A, and the transporter will complete Part B (vehicle details) on the portal . The transporter (or person in charge of conveyance) may generate Part B details (vehicle number, transporter ID) once consignment starts moving. For rail/air/ vessel transport, either supplier or recipient generates the e-way bill and furnishes Part B before or after movement . Importantly, the e-way bill number (EBN) must be obtained before commencement of movement. The portal then makes the EBN available to the supplier, recipient and transporter.

Exemptions & Exceptions: Rule 138(14) lists cases where no e-way bill is needed . Key exemptions
include: transport of goods specified in the Annexure (e.g. LPG to domestic households, kerosene under PDS, currency, personal effects) ; goods in transit under customs supervision or to CFS/ICD; transit cargo to Nepal/Bhutan; goods exempt from GST under notification; defense consignments; Central/ State Govt cargo by rail; empty containers; and short movements (≤20 km to a weighbridge, subject to a delivery challan) . Non-motorized transport also requires no e-way bill. In addition, goods
under Chapter 71 (precious stones, metals, jewellery) have a separate special (lower) limit. Always check the latest CGST rules or State notifications for specific exempted categories.

Validity & Extensions: Once generated, the validity of an e-way bill depends on distance . For
ordinary cargo, it is valid for 1 day per 200 km (or part thereof) from the time of generation . For
example, up to 200 km = 1 day; 200–400 km = 2 days, etc. For over-dimensional cargo (ODC), validity is 1 day per 20 km (up to 20 km = 1 day; each additional 20 km adds a day) . The count starts at
generation time (see Explanation 1 in Rule 138). By Notification, the GST Commissioner can extend
validity for specified goods (e.g. perishable items). Importantly, if a consignment cannot be delivered within validity due to exceptional reasons (e.g. transshipment), the transporter may extend validity by
updating Part B . Also, as per an amendment, an e-way bill may be extended within 8 hours of its
expiry (i.e. 8-hour grace period). Extensions can only be done on the portal by the transporter (the
person who last updated Part B).

Document Parts A & B: The e-way bill form (GST EWB-01) has two parts . Part A (to be filled by
consignor/consignee) includes: GSTIN of supplier, place of dispatch, GSTIN of recipient (or “URP” if
unregistered), place of delivery (PIN), document number/type (invoice/challan), date, value, HSN codes, and reason for transportation . Part B (to be filled by transporter or consignor) includes: Mode of transport, transporter name, transporter ID, transport document number (e.g. LR/RR/BL), and vehicle number(s) . The consignor must ensure all details (especially HSN, values, GSTINs) are accurate. Once Part B is furnished, the portal validates the data. Upon successful submission, a unique 12-digit EWB number is generated . This EWB must be noted on invoices/delivery challans and carried along with the goods. 

Step-by-Step Generation (Portal): To create an e-way bill on the official portal (https://
ewaybillgst.gov.in) one typically follows these steps:

 1. Registration/Login: The business (as a registered taxpayer) or transporter must first register on the     portal. Log in using the GSTIN credentials (or transporter ID) .
2. Select “Generate E-Way Bill”: In the menu, choose E-Waybill > Generate New.
3. Fill Part A (Transaction Details): Enter transaction type (Outward/Inward), document type (Invoice/
    Bill/Challan), document number and date, supplier GSTIN (auto-populated if login is supplier), place     of dispatch, recipient GSTIN/place (for outward) or vice versa for inward, and brief item details             (HSN, quantity, value, tax rate, total) .
4. Fill Part B (Transporter Details): Enter mode of transport (Road/Rail/Air/Ship) , transporter name
    and ID, transport document number and date (e.g. consignment note), and vehicle number (if goods
    moving by road) . Approximate distance can be entered as required.
5. Preview & Submit: Review all details carefully. Click Submit. The portal will validate inputs. If errors
    occur (e.g. incorrect GSTIN, mismatch), correct them. Upon success, the portal generates the EWB-     01 with a 12-digit E-way Bill Number. The system also forwards the EWB to the transporter’s portal       (if different) where the vehicle number can be updated if needed .
    

(Note: Part A can be pre-filled using masters or bulk templates on portal; transporters can log in            separately to update Part B if consignor didn’t.)

Compliance Obligations: The taxpayer must carry a copy of the e-way bill (printed or e-copy) during
transit. Transporters must present the EWB when required by tax authorities. Businesses should
maintain records of all e-way bills generated (and cancelled) as part of statutory accounts. Rule 138(11–12) even provides an acceptance/rejection mechanism: the supplier or recipient (as applicable) can log in and accept or reject the e-way bill details within 72 hours, after which silence implies deemed acceptance . In practice, enterprises should reconcile e-way bills with sales returns (GSTR-1) and transport records. The Part A data of every e-way bill is auto-shared on the GST portal and can be used to auto-populate GSTR-1 data . 

Penalties for Non-Compliance: Transporting goods without a valid e-way bill (when one is required) is a serious offense. Section 122(1)(xiv) of the CGST Act penalizes any person who “transports any taxable goods without the cover of documents as specified” . The penalty is ₹10,000 or the tax amount (whichever is higher) . Additionally, under Section 129, goods in transit without an e-way bill can be detained or seized; to release them, the transporter must pay tax plus a penalty (typically 20% of tax or ₹25,000, whichever is lower). For certain high-value goods (tobacco, etc.) police or other officers are empowered to detain vehicles. Repeated non-compliance may attract prosecution. In sum, failing to generate (or carrying an invalid) e-way bill exposes the supplier/recipient/transporter to heavy fines and freight delays.


E-Invoicing (Rule 48 CGST Rules)



Meaning & Legal Basis: “E-invoicing” under GST means electronically reporting invoice data of B2B
supplies to a notified Invoice Registration Portal (IRP) to obtain an Invoice Reference Number (IRN)
and a digital QR code . The requirement is mandated by Section 148 of the CGST Act and
implemented by Rule 48(4) of CGST Rules (inserted by Notification 68/2019–CT dated 13 Dec 2019) .
Rule 48(4) states that notified classes of registered persons must issue invoices in FORM GST INV-01
after uploading them on the portal and obtaining an IRN . Sub-rule (5) clarifies that any invoice not
issued via this process will not be treated as a valid tax invoice . In effect, once e-invoicing is mandated for a taxpayer, all their B2B (and related) invoices must be generated as e-invoices. E-invoicing standards align GST invoicing with the Income-tax and Companies Act requirements, ensuring uniformity.

Applicability & Thresholds: E-invoicing was rolled out in phases based on Aggregate Annual Turnover
(AATO). Initially it applied to AATO >₹500 crore (from 1 Oct 2020), then to >₹100 crore (1 Jan 2021),
>₹50 crore (1 Apr 2021), >₹20 crore (1 Apr 2022), and >₹10 crore (1 Oct 2022) . Most recently,
Notification 10/2023–CT (dated 10 May 2023) lowered the limit to ₹5 crore AATO , effective
1 Aug 2023. (AATO is measured as turnover of all GSTINs under a PAN in any FY from 2017–18 onward.) Thus, for FY 2024–25, all businesses with AATO exceeding ₹5 Cr in any previous year must issue einvoices. Note: once a taxpayer crosses the threshold in one FY, they must start e-invoicing at the start of the next FY , and continue even if turnover later falls below the threshold . The rules exempt certain categories: insurers, banks and financial institutions (including NBFCs), goods transport agencies (GTA), passenger transport operators, multiplex services (cinema tickets), and persons under OIDAR rule (online sellers) are not required to issue e-invoices . Recent GST Council meetings have even proposed phasing in e-invoicing for B2C invoices in future (post FY 24-25).

Invoice Reference Number (IRN) & QR Code: When an e-invoice is reported to the IRP, the system
generates a unique 64-bit Invoice Reference Number (IRN) – effectively a hash of key invoice fields –
which must be printed on the invoice . Concurrently, the IRP issues a digitally signed QR code
containing crucial invoice data (e.g. GSTINs, IRN, invoice number, invoice date, total value, and unique
hash) . This QR code (minimum 50×50 mm) must be printed on every e-invoice (especially for B2B
supplies, typically mandatory if invoice value ≤₹50,000 and recommended in general). The QR code
allows offline scanning by tax officials for verification. Thus a valid e-invoice is one that has been
uploaded to the IRP, assigned an IRN, and contains the IRN and QR code, along with the supplier’s
digital signature (the IRP signature) . Any invoice issued outside this process (when e-invoicing is
mandated) is deemed invalid .

Process to Generate an E-Invoice: E-invoices are created by submitting invoice data (in a prescribed
JSON schema) to an authorized Invoice Registration Portal (the Govt‐run portal or GSPs enabled for
e‑invoicing, e.g. einvoice1.gst.gov.in). 

The steps are:

 1. Prepare Invoice: Generate your regular tax
invoice (FORM GST INV-01 format) in accounting/ERP software, ensuring all mandatory fields (e.g.
GSTIN of seller/buyer, HSN, tax values) are filled. Ensure your business is above the AATO threshold and not exempt.

 2. Upload to IRP: Transmit the invoice JSON to the IRP (many ERPs have e-invoicing
integration; or use bulk upload/API). This must be done within 24 hours of invoice issue (soon to be 30
days for >₹10 Cr businesses post-1 Apr 2025). 

3. Receive IRN and QR: The IRP validates the invoice
(checks GSTINs, duplicates, schema). If accepted, it returns the IRN and digitally signed JSON with the QR code data. If there are errors (see below), correct and re-submit. 

4. Print Final Invoice: Incorporate the IRN and QR code on the printed/final invoice copy given to the buyer. Your copy, the buyer’s copy, and transporter copy all carry the IRN and QR.

E-invoice generation can be done via the web portal or integrated APIs – most medium/large
businesses automate this via their billing software. Each IRP logs the IRN against the invoice data; deduplication ensures an invoice isn’t registered twice . Once an IRN is issued, no further changes to
the invoice are permitted (other than cancellation). 

Integration with GSTR-1 and GST Portal: The e-invoicing system directly shares invoice data with GSTN. In fact, Rule 48(6) contemplates auto-population: once an IRN is generated, the invoice details
flow into the GST portal. This makes GSTR-1 filing largely seamless – data entry becomes redundant as invoices are pre-populated . The portal flags the e-invoices under the supplier’s GSTR-1 (or for
recipient under GSTR-2A/2B). For the buyer, the transaction appears in their electronic ledgers
automatically (auto-populated in GSTR 2B) , greatly simplifying ITC claim reconciliation. In contrast,
traditional invoices required manual upload in GSTR-1 and manual entry by the buyer; e-invoicing
eliminates this duplication and reduces mismatch errors.

Differences from Traditional Invoices: A traditional invoice under GST was simply generated by the
seller (triplicate/duplicate, manual or digital) and reported in returns. An e-invoice, however, is
electronically authenticated on the government portal. Key differences: (a) Standard Format: Einvoices
use a unified schema (Form INV-01), whereas traditional invoices could vary in format (subject
to containing mandated fields). (b) Real-time Reporting: E-invoice data is reported in real time to IRP,
whereas traditional invoices were only reported later via GSTR-1. (c) Mandatory QR and IRN: E-invoices carry an IRN and QR code, which traditional invoices do not. (d) Validity: If e-invoicing is mandated, issuing an invoice in any other manner renders it invalid . (e) ITC Advantage: E-invoices ensure instant appearance in the buyer’s GSTR-2B (if the recipient is registered), facilitating ITC claims. By contrast, with traditional invoices, there could be delays or missing entries.

Common Errors & Troubleshooting: Businesses often face a few typical errors on the IRP. Examples
include: Duplicate IRN (error 2150/2154) if the same invoice is submitted twice ; Missing Fields (e.g.
error 2155 “Supplier GSTIN is required” if a mandatory field is blank) ; Invalid Data (e.g. incorrect
GSTIN format, wrong HSN, or inconsistent values); or Connectivity/Server Errors on IRP. To
troubleshoot, ensure you only send each invoice once (check your system’s log of IRNs before retrying). Verify that the JSON strictly follows the schema (GSTIN 15-digit format, invoice number format, valid tax rates). If the IRP is down or slow, try again later or use alternate portals. In case of persistent technical issues, the GST helpline and IRP FAQs (einvoice6.gst.gov.in) provide solutions. Always record the IRN and response status (success or error) from the IRP in your system for audit trail and review.

Impact on ITC: E-invoicing significantly aids Input Tax Credit (ITC) management. Since every e-invoice
is shared instantly with the recipient’s GST portal, eligible ITC becomes available in the buyer’s electronic ledger without waiting for invoice upload. This reduces mismatches between GSTR-2A/2B and books. Moreover, since e-invoices follow a standard digital format, incorrect entries or fraud are easier to detect. In short, timely e-invoicing helps ensure that ITC is claimed correctly and quickly. (Note: ITC can only be claimed if the invoice is valid and reported; failing to upload a mandated e-invoice can delay or forfeit ITC).

Filing Compliance: Impact on GST Returns and Records

  • Effects on GST Returns: Both e-way bills and e-invoices interface with GST return filings. For GSTR-1,
    the Part A data of each e-way bill (invoice-level details) is available on the portal to populate return fields. Similarly, e-invoice data auto-populates in GSTR-1 (as per Rule 48). Thus, businesses have less
    manual work in preparing GSTR-1. For GSTR-3B (monthly summary return), these systems have indirect effects: more accurate reporting of outward supplies (due to e-invoices) and input claims (due to autoupdated ITC) generally lead to consistency. However, taxpayers must still reconcile totals (e.g. ensure that the sum of values in e-invoice/GSTR-1 equals GSTR-3B taxable turnover). The Government has clarified in circulars that generating an e-invoice itself does not replace the need to file returns; it only pre-fills parts of them.

    Recordkeeping & Audit Trail: Taxpayers must keep clear records linking e-invoices, e-way bills, and
    returns. This means maintaining copies (electronic or printed) of: all e-invoices issued (with IRN, QR), all e-way bills (Form EWB-01/PDF), invoices/delivery challans, and related transport documents. These
    should be preserved as per GST record rules (typically 6 years). Auditors will match e-invoice data
    against the company’s books and GSTR-1; they will also verify that every high-value outward
    consignment had a valid e-way bill. Proper reconciliation (e.g. cross-checking that every outward invoice above ₹50K has an EWB, and that every e-way bill’s Part A data matches an invoice) is now a standard compliance step.

     Due Dates & Recent Amendments: The introduction of e-invoicing and e-way rules has led to some deadline changes. Key dates and updates for FY 2024–25 include:
     
  • E-Invoice Reporting Window: Effective 1 Apr 2025, businesses with AATO ≥₹10 Cr must upload
    e-invoices within 30 days of invoice date (previously this was effectively 24 hours). In other
    words, from Apr 2025 such businesses cannot report an e-invoice late beyond 30 days. (No
    similar strict timeline exists yet for smaller taxpayers.) 
  • E-Way Bill Validity Extensions: As noted, Rule 138 now explicitly allows a one-time 8-hour postexpiry extension of an e-way bill . This was inserted by CBIC to reduce loss from very short delays. GSTR-1/3B Due Dates: The normal deadlines remain: GSTR-1 is due by the 11th of the next
    month (for turnover >₹5 Cr) or quarterly by the 13th (upto ₹5 Cr); GSTR-3B due by the 20th of the
    next month (for large taxpayers) or 22nd (others). However, many experts recommend finalizing
    e-invoice and e-way bill data well before these due dates.
  • GST Council Circulars/Notifications: Recent GST Council decisions affecting FY 24-25 include
    the above Notification No. 10/2023–CT (5 Cr threshold) and related Circulars (e.g. clarifying
    the e-invoice submission timeline). CBIC circulars have also clarified that e-way bills need not be
    carried for very short transport legs (the 50 km exemption) and that Part A of e-way can be
    updated by transporters on the supplier’s behalf by authorization .
  • Compliance Reminders: Tax authorities periodically issue advisories. For example, they remind
    that once e-invoicing is mandated, failing to upload invoices means they cannot be considered
    valid; hence ITC cannot be claimed on such invoices and the supplier cannot claim output tax.

For e-way bills, authorities have cautioned that genuineness of EWB data will be checked during
transit and audits. Businesses should watch for any State-specific GST notifications (e.g.
intrastate relaxation) or additional compliance features (like SMS updates) on the GST portal.

Summary: In practice, the rise of e-way bills and e-invoicing means that GST compliance is now heavily digital and real-time. Accountants and compliance officers must integrate their billing, transport, and accounting systems with the GST common portals, ensure timely data entry/upload (invoice on day of sale, e-way before dispatch), and reconcile these electronic records against returns. This ‘pre-reporting’ of transactions increases transparency and reduces errors, but requires disciplined recordkeeping. By FY 2024–25, e-invoicing and e-way rules have become standard parts of GST compliance for medium and large businesses, and staying updated on related amendments (via CBIC notifications and circulars) is critical.