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In most cases, a registered person moving goods in India must ensure an e-way bill is furnished before transport begins when the consignment value exceeds ₹50,000. The rule covers movement for a supply, movement for another reason, and inward movement from an unregistered supplier. The consignor, consignee or transporter may generate the bill, depending on the transport arrangement. Named goods, transport methods, customs movements and notified areas are exempt, while certain interstate job-work and handicraft consignments require an e-way bill even below the normal threshold.
The basic rule: when an e-way bill is required
Rule 138 of the Central Goods and Services Tax (CGST) Rules generally applies when a registered person causes goods to move and the consignment value exceeds ₹50,000. The information must be furnished on the e-way bill system before the movement starts, not after the vehicle has already departed.
The trigger is broader than a normal sale. It includes movement:
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- For a reason other than supply, such as a return, repair, exhibition, branch transfer or other business movement; and
- Because of an inward supply from an unregistered person.
“Exceeding ₹50,000” means the ordinary central-rule threshold is crossed only when the relevant consignment value is more than ₹50,000. It is not a universal exemption for every lower-value consignment: special rules can require a bill regardless of value, and a state or Union Territory can have additional notification-based requirements.
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Who is legally responsible, and who can press Generate?
The person who causes the qualifying movement is responsible for ensuring that the movement is documented. That does not always mean the same person physically generates the number.
Consignor
A registered consignor can generate the e-way bill when dispatching goods. This is common where the seller arranges transport or hands the goods to a carrier after preparing the invoice or delivery document.
Consignee
A registered recipient acting as consignee can generate the bill when the recipient arranges transport or otherwise controls the movement. The recipient may therefore be the generator even though the supplier issued the invoice.
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If a registered person hands the goods to a road transporter and no e-way bill has been generated through the consignor or consignee route, the registered person furnishes the transporter’s information and the transporter can generate the bill using the Part A information supplied for the consignment.
The official e-way bill portal also recognises the consignor, consignee and transporter as possible generators. An unregistered transporter must enrol on the e-way bill portal before generating one. In practice, businesses should agree in advance who will enter the details and who will verify the final number, because an allocation of data-entry work does not remove the underlying compliance responsibility.
How consignment value is calculated
For the threshold test, the official portal FAQ states that declared consignment value includes applicable central tax, state or Union Territory tax, integrated tax and cess. Freight charged by the transporter for moving the goods is excluded.
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Where one invoice contains taxable and exempt goods, the value of the exempt goods is excluded from the declared consignment value under that FAQ. The exclusion applies to the value calculation; it does not turn every GST-exempt product into an automatic e-way bill exemption. Whether the goods themselves are exempt from the bill must still be tested against the specific Rule 138(14) schedule, notification and movement conditions.
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- A taxable consignment priced at ₹45,000 with ₹8,100 of applicable GST has a declared value of ₹53,100 before any separately charged transporter freight. It crosses the ordinary threshold.
- If an invoice contains ₹20,000 of exempt goods and ₹40,000 of taxable goods plus ₹7,200 tax, the FAQ treatment excludes the exempt-goods value. The relevant declared value is therefore ₹47,200, before excluding transporter freight, subject to the exact invoice and transaction facts.
These examples explain the arithmetic only. They do not override a special interstate job-work or handicraft rule, a local notification or a goods-specific exemption.
Exempt transactions and movements
The following are the principal no-e-way-bill categories described in the cited Rule 138 text and official clarification. The list should not be treated as a guaranteed complete list of every later central, state or Union Territory amendment.
| Exemption route | What it covers | Condition to verify |
|---|---|---|
| Goods in the Rule 138(14) annexure | The retrieved annexure names LPG supplied to household and specified non-domestic exempt-category customers; kerosene sold through the Public Distribution System; postal baggage transported by the Department of Posts; specified Chapter 71 pearls, precious and semi-precious stones, precious metals and jewellery; currency; used personal and household effects; and specified unworked or worked coral. | Confirm that the exact product and description fall within the current annexure wording. |
| Non-motorised conveyance | Goods transported by a conveyance that is not motorised. | Verify that the actual vehicle or conveyance meets the rule’s meaning; do not assume a motor vehicle is covered because the trip is short. |
| Customs clearance movement | Goods moving from a port, airport, air cargo complex or land customs station to an inland container depot (ICD) or container freight station (CFS) for customs clearance. | Check the customs status, origin and destination facilities. |
| Notified local areas | Movement within areas notified under the applicable state or Union Territory rules. | Read the current local notification for the particular area and movement. |
| Specified exempt goods | Goods listed in the schedule to Notification No. 2/2017-Central Tax (Rate), other than de-oiled cake. | Use the current schedule and amendments; a general label such as “exempt goods” is insufficient. |
| Excluded GST categories | Alcoholic liquor for human consumption, petroleum crude, high-speed diesel, petrol (motor spirit), natural gas and aviation turbine fuel. | Confirm that the product is the named category, not a similar product with a different legal classification. |
| Schedule III activities | Transactions treated as “no supply” under Schedule III of the CGST Act. | Establish that the transaction actually falls under Schedule III rather than merely being described internally as a non-sale. |
| Customs-supervised movements | The official clarification also identifies specified export cargo movements from customs ports, airports, air cargo complexes or land customs stations to an ICD or CFS; specified customs-bond movements between an ICD/CFS and customs locations or between customs locations; and movement under customs supervision or customs seal. | Retain the customs documents and confirm that the route and supervision match the clarification. |
Many of these are conditional exemptions. For example, the fact that a product is exempt from GST does not by itself establish that an e-way bill is unnecessary. The referenced schedule, product entry, destination, transport mode and customs status can all matter.
Movements that can require a bill below ₹50,000
Interstate job work
Rule 138 contains special provisions for certain interstate movements sent for job work. Where the specified conditions apply, an e-way bill can be required irrespective of consignment value. A business should therefore identify the job-work relationship, the state-to-state route and the documents accompanying the goods before relying on the ordinary threshold.
Interstate handicraft goods
Special treatment also applies to specified interstate movements of handicraft goods. These consignments can require an e-way bill even when the value does not exceed ₹50,000. The product must meet the relevant handicraft description and the movement must satisfy the interstate rule; a business should not apply this exception to every handmade item without checking the classification.
A practical decision process before dispatch
- Identify the movement. Record whether it relates to a supply, another business reason or inward supply from an unregistered person.
- Identify the parties. Note the registered consignor, registered consignee, transporter and, where relevant, the unregistered supplier.
- Calculate declared consignment value. Include applicable GST and cess, exclude transporter freight, and apply the FAQ treatment for exempt goods in a mixed invoice.
- Test the ordinary threshold. If the value exceeds ₹50,000, plan to furnish the information before movement begins.
- Test special rules. Check interstate job work, interstate handicraft movement and any other rule that applies irrespective of value.
- Test each exemption route. Check the Rule 138(14) annexure, Notification No. 2/2017-Central Tax (Rate), the transport mode, customs status and the applicable state or Union Territory notification.
- Assign the generator. Decide whether the consignor, consignee or transporter will generate the bill. If a road transporter is generating it, provide complete Part A information and confirm the transporter’s enrolment where required.
- Complete the required vehicle information. Enter the transport details required by the portal before the vehicle starts, and update them when the transport arrangement changes in accordance with the portal rules.
- Verify the final record. Match the e-way bill number and goods description against the invoice, delivery challan or other document carried with the consignment.
- Retain evidence. Keep the invoice or delivery document, transport details, exemption analysis and any customs or local notification evidence with the transaction records.
Examples of common outcomes
Domestic sale above the threshold
A registered seller sends taxable goods to a registered buyer, and the declared value including applicable tax is ₹75,000. No listed exemption applies. The seller or buyer can generate the bill, or the transporter can do so through the transporter route when the required Part A information is supplied. The information must be furnished before dispatch.
Low-value repair return
A customer returns equipment for repair with a declared value of ₹30,000. Because the movement is for a reason other than supply, it is within the scope of the rule’s subject matter, but the ordinary central threshold is not crossed. The business must still check whether a special rule or local notification applies and should carry the appropriate delivery or return document.
Consignment of listed petroleum product
A movement consists of high-speed diesel, one of the named excluded categories. The goods-based exclusion may remove the e-way bill requirement under the cited rule, but the business should verify the current product classification and any separate documentation imposed by another law or local order.
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A registered manufacturer sends a qualifying job-work consignment to another state valued at ₹35,000. The ordinary threshold is not crossed, but the special interstate job-work provision may still require an e-way bill. The route and job-work facts must be checked before dispatch.
Frequent mistakes and how to correct them
- Assuming ₹50,000 is a blanket exemption: Check special interstate categories and local notifications.
- Using the invoice subtotal as the value: Apply the tax, cess, exempt-value and transporter-freight rules rather than copying an arbitrary subtotal.
- Confusing GST exemption with e-way bill exemption: Match the product to the named schedule or annexure entry.
- Waiting until a vehicle is stopped: Furnish the information before movement begins and ensure the driver or carrier has the required number or record.
- Assuming only the seller can generate: The consignee and transporter can also be authorised routes, depending on the arrangement.
- Ignoring customs conditions: A customs-related movement is exempt only when its facility, route, bond, seal or supervision condition matches the applicable rule.
- Relying on an old local notification: Recheck the state or Union Territory notification for the date of movement.
How to handle uncertain or changing exemptions
The central-rule summary above is based on the retrieved CBIC Rule 138 text and a 22 March 2018 Press Information Bureau clarification. The available rule compilation is historical and does not establish that every amendment in force on 13 October 2026 has been captured. State and Union Territory notifications can also create area-specific treatment.
For a high-value or unusual movement, document the exact legal basis for not generating a bill: the annexure entry, notification paragraph, customs document, non-motorised conveyance fact or local-area notification. If no current source clearly supports the exemption, the safer compliance approach is to obtain professional GST advice and verify the latest consolidated CGST Rules and the applicable local notification before dispatch.
Quick Recap
What to remember
- The ordinary central trigger is a consignment value above ₹50,000.
- The movement must be documented before it begins.
- The consignor, consignee or transporter may generate the bill, depending on the arrangement.
- Value includes applicable GST and cess, but the official FAQ excludes transporter freight and, in a mixed invoice, the value of exempt goods.
- Named goods, transport methods, customs routes, Schedule III transactions and notified areas can be exempt.
- Specified interstate job-work and handicraft movements can require an e-way bill below the ordinary threshold.
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