Home Knowledge HubE-Way Bill Compliance: Rules, Exceptions, and Common Mistakes

GST|November 202513 min readArticle

E-Way Bill Compliance: Rules, Exceptions, and Common Mistakes

When an e-way bill is required, who must generate it, the 200-km-a-day validity arithmetic, the 2025 document-date and 360-day extension caps, and how to keep your trucks out of Section 129 detention.

Key takeaways

An e-way bill is mandatory for movement of goods when the consignment value exceeds ₹50,000. Inter-state: ₹50,000 is uniform across the country; intra-state: states can notify higher thresholds (several have — check your state).

Validity is 1 day for every 200 km (or part thereof) for normal cargo; 1 day per 20 km for over-dimensional cargo. The clock starts only once Part B (vehicle details) of Form EWB-01 is filled.

Effective 1 January 2025, e-way bills can only be generated for documents dated within the last 180 days; the maximum extension window is capped at 360 days from the original generation date.

Section 129 penalties on detention are severe: 200% of tax payable (or 2% of value / ₹25,000 for exempt goods, whichever is lower) if the owner comes forward, and up to 50% of the value of goods if the owner does not come forward.

The most common detention triggers are operational, not malicious: vehicle change not updated in Part B, expired validity, mismatched HSN/value, missing e-way bill for stock transfers, and job-work movement without an e-way bill despite it being mandatory above ₹50,000.

When an E-Way Bill is Required (and When It Is Not)Who Generates the E-Way Bill Form EWB-01: Part A, Part B, and Validity Section 129: The Detention Penalty Stack Common Mistakes That Trigger Detention A Practical Logistics Desk Workflow

01When an E-Way Bill is Required (and When It Is Not)

Section 68 of the CGST Act read with Rule 138 of the CGST Rules, 2017 makes an e-way bill mandatory before any movement of goods of consignment value exceeding ₹50,000. The rule applies to supplies, returns, job work, and inward supplies from unregistered persons — not just outward sales.

Inter-state vs intra-state

–Inter-state movement: ₹50,000 threshold applies uniformly across all states and UTs. No exceptions.

–Intra-state movement: States may notify a higher threshold. For example, several states have set ₹1,00,000 or ₹2,00,000 for intra-state movement of specific goods. Check your state's notification before assuming the central threshold applies.

Mandatory e-way bill even below ₹50,000

–Inter-state movement by a principal to a job worker (irrespective of value).

–Inter-state movement of handicraft goods by a supplier exempt from GST registration (irrespective of value).

When an e-way bill is NOT required

–Movement of goods specified in the Annexure to Rule 138(14) — typical items include LPG for household use, kerosene under PDS, postal baggage by the Department of Posts, precious/semi-precious stones, and used personal/household effects.

–Goods treated as no supply under Schedule III of the CGST Act (e.g., services by an employee, sale of land/building).

–Movement by non-motorised conveyance.

–Movement from a port/airport/air cargo complex/land customs station to an inland container depot/container freight station for Customs clearance.

–Where the distance from the consignor/consignee to the transporter is up to 50 km within the same state (Part B not required — a reduced e-way bill can be generated).

Stock transfers and job-work are not exempt

A recurring error is assuming e-way bills are only for 'sales'. Movement of stock between two GSTINs of the same PAN is a taxable supply under GST (even without consideration) and requires an e-way bill above ₹50,000. Job-work dispatches and returns equally require e-way bills. These are top detention triggers for SMEs.

02Who Generates the E-Way Bill

Responsibility depends on the scenario. Getting this wrong is a common cause of duplicate or missing bills.

E-way bill generation responsibility

Scenario	Primary responsibility	Alternate
Supplier is registered; transports in own vehicle	Supplier (fills Part A + Part B)	—
Supplier is registered; goods handed to transporter	Supplier (fills Part A); transporter fills Part B	Supplier can fill Part B if vehicle known
Supplier is unregistered, recipient is registered	Recipient (deemed supplier for e-way bill purposes)	—
Supplier is unregistered, goods to unregistered recipient	Transporter, if they carry out the movement	Either party may voluntarily generate
Inter-state movement by principal to job worker	Principal (regardless of value)	—
Movement for own use across GSTINs (stock transfer)	Sending GSTIN	—

03Form EWB-01: Part A, Part B, and Validity

Part A — invoice/document details

–GSTIN of supplier and recipient, invoice/document number and date, HSN, value, tax rate, place of delivery, reason for transportation.

–Part A cannot be edited once submitted — incorrect entries require cancellation and regeneration (which must be done within 24 hours of generation).

–Part A alone does not make an e-way bill valid for road movement; Part B is mandatory (except for the intra-state short-distance carve-out).

Part B — vehicle details

–Vehicle number (or transporter document number for rail/air/ship).

–Part B can be updated any number of times within the validity period — vehicle change, trans-shipment, breakdown, etc.

–The e-way bill becomes valid for road movement only after Part B is filled. The validity clock starts at this point.

Validity period

E-way bill validity by distance

Cargo type	Validity rule
Normal cargo	1 day for every 200 km (or part thereof)
Over-dimensional cargo (ODC)	1 day for every 20 km (or part thereof)
Multimodal (including ship transport)	Same per-km rules; validity can be extended by transporter if shipment delayed

Worked example: A Vadodara-to-Chennai consignment of approximately 1,850 km has a validity of 10 days (1 day for 0–200 km plus 9 additional days for the remaining distance). A Delhi-to-Mumbai shipment of ~1,400 km would have a 7-day validity.

January 2025 caps you must know

From 1 January 2025, (a) e-way bills can only be generated for documents whose date is within the last 180 days, and (b) the maximum extension is capped at 360 days from the original generation date. Both are guardrails against misuse of very old documents or indefinite extensions.

04Section 129: The Detention Penalty Stack

Section 129 of the CGST Act empowers officers to detain or seize goods and the conveyance moving without a valid e-way bill (or with material discrepancies in one). The penalty stack is sharp and the release mechanic is procedural — knowing the rules reduces the financial exposure materially.

Section 129 penalties on detention

Situation	Penalty (to release goods)
Owner comes forward — taxable goods	200% of tax payable on the goods
Owner comes forward — exempt goods	2% of the value of goods or ₹25,000, whichever is lower
Owner does not come forward — taxable goods	50% of the value of goods reduced by tax paid (cash penalty portion)
Owner does not come forward — exempt goods	5% of the value of goods or ₹25,000, whichever is lower
Conveyance release	Penalty amount (above) or ₹1,00,000, whichever is less

Beyond the base penalties, a general penalty of ₹10,000 or the tax sought to be evaded (whichever is greater) may be levied for transporting taxable goods without the cover of an e-way bill. A separate ₹100 per km penalty can be imposed on the distance for which goods have been transported without an e-way bill, depending on the officer's view of the facts.

Procedural timeline

–The proper officer issues a notice specifying the tax and penalty payable, within seven days of detention or seizure.

–The person must pay the notified amount within seven days of notice to get the goods released.

–If no payment is made, confiscation proceedings under Section 130 can be initiated.

–An appeal lies with the Joint/Additional Commissioner (Appeals) against the detention order.

High Court rulings on technical breaches

Multiple High Courts have held that where the movement is genuine and there is no intent to evade tax, detention for technical lapses (typo in vehicle number, expired validity by a few hours, minor HSN mismatch) should not carry full Section 129 penalty. Document the genuineness of the transaction carefully — an officer is more likely to release on nominal penalty where the paper trail is clean.

05Common Mistakes That Trigger Detention

01Expired validity mid-journey. Truck breaks down or gets rerouted; validity expires; driver continues without updating Part B. Update Part B immediately and extend under the transporter's login if required.

02Vehicle change not recorded. Trans-shipment or vehicle swap at a transit point without updating Part B leaves the e-way bill invalid for the new vehicle.

03Stock transfer treated as non-taxable. Movement between two GSTINs of the same PAN still requires an e-way bill above ₹50,000 — it is a deemed supply under GST.

04Job-work dispatch without an e-way bill. Inter-state job-work movement by the principal requires an e-way bill irrespective of value.

05Part A entered wrong, not cancelled within 24 hours. Once 24 hours lapse, the erroneous e-way bill cannot be cancelled. Generate a fresh one and keep both on record with a narration.

06HSN / value mismatch with invoice. The e-way bill value must match the invoice. Rounding differences are acceptable; material mismatches draw scrutiny.

07Missing e-way bill for intra-state movement assumed exempt. Several taxpayers incorrectly assume intra-state exemption when their state actually requires it above ₹50,000.

08Unrelated documents combined. Two separate invoices under one e-way bill below the individual ₹50,000 threshold is risky — officers often read aggregate value and insist on compliance.

06A Practical Logistics Desk Workflow

Pre-dispatch (T-60 minutes)

–Generate e-way bill with complete Part A (invoice, HSN, value, GSTINs).

–Confirm vehicle number with transporter; fill Part B.

–Validate approximate distance (Google Maps / portal auto-compute) and ensure validity is sufficient.

–Share PDF with driver and transporter via WhatsApp/portal.

In-transit monitoring

–Track ETA against validity expiry; flag shipments where expiry could be tight.

–For trans-shipment, update Part B with new vehicle number as soon as known.

–For delays (breakdown, weather, route change), extend validity via the e-way bill portal under the transporter's login — extension window is limited; act within four hours of expiry, ideally before.

At detention (if it happens)

–Ask the officer to issue Form GST MOV-06 (detention order) and Form MOV-07 (notice of tax/penalty).

–Engage counsel or the firm's GST team immediately — early representation often reduces penalty in genuine cases.

–If tax/penalty is clearly payable, pay via DRC-03 to expedite release and pursue refund through appeal if aggrieved.

–Preserve all communications, invoices, purchase orders, delivery challans, and prior e-way bills — the paper trail matters in appeal.

Monthly and quarterly governance

–Reconcile e-way bills generated with GSTR-1 outward supplies (value, HSN, recipient GSTIN).

–Monitor cancelled e-way bills — excessive cancellation draws scrutiny.

–Review pending e-way bills from transporter's login that are showing as assigned but not closed out.

–Train drivers and transporters on what documents they must carry and what to do at checkpoints.

Treat e-way bill like a cheque

It's a small administrative document that, mishandled, can cost you the value of the truck. A disciplined logistics desk with a checklist and a clear escalation path handles 95% of problems at source — long before they become Section 129 cases.

CA Siddharth A Shah

CA Siddharth A Shah & Associates, Vadodara

This article is for informational purposes only and does not constitute professional advice. Tax laws are subject to change. Readers should consult a qualified Chartered Accountant for advice specific to their situation. Published November 2025.

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