01 May 2026
As per Rule 138 of the GST, it is understood that an e-way bill is not required when goods are transported by a non-motorised conveyance. A friend informed me that during a separate inquiry, a GST officer reviewed certain transactions of his company and observed that e-way bills had not been generated for a few invoices. He clarified that the goods were dispatched via hand carts (the distance was also short), and therefore, e-way bills were not applicable. The value per invoice was approximately ₹1–1.5 lakhs, which can reasonably be transported through such means, with no indication of any irregularity. However, the officer maintained that, as per the rules, at least Part A of the e-way bill must be generated. His consultant also concurred with this view. Can you please share your expert opinion on this ?
01 May 2026
In my view, the officer’s stand is safer. Where the consignment value exceeds ₹50,000, Rule 138(1) requires furnishing of details in Part A of FORM GST EWB-01 before commencement of movement, unless the goods/movement fall under a specific exemption. Movement through hand cart/non-motorised conveyance may justify non-furnishing of vehicle details/Part B, but it should not be read as a blanket exemption from Part A. Therefore, for invoices of ₹1 lakh–₹1.5 lakh, the better compliance approach is to generate Part A and keep invoice, delivery proof and movement records. If Part A was not generated earlier due to bona fide interpretation, the taxpayer may explain the facts, short distance, non-motorised movement and absence of tax evasion intent, but going forward Part A should be generated.