E-Way Bills in Special Cases

The e-way bill form is built around a simple trip. One supplier sends goods on one invoice to one buyer, in one truck, by road. Many movements are not like that. Goods may go to a job worker and come back. They may be billed to one party and delivered to another. A machine may be shipped in parts over a week, or cross the border for export. A consignment may change from rail to truck, or travel to a trade fair and back unsold. The seller may be unregistered.

Each of these has its own provision, circular or portal setting, and getting it wrong is a common reason for detention. This guide takes them in turn. It assumes the general rules in E-Way Bills: When One Is Needed and Generating, Extending and Cancelling an E-Way Bill.

Job work

When a bill is needed. For intra-State movement, the ordinary threshold applies. For inter-State movement, the third proviso to rule 138(1) removes it:

where goods are sent by a principal located in one State or Union territory to a job worker located in any other State or Union territory, the e-way bill shall be generated either by the principal or the job worker, if registered, irrespective of the value of the consignment.

Who generates it. Circular No. 38/12/2018-GST (26 March 2018), paragraph 8.3, reads that proviso with Explanation 1 to rule 138(3). It concludes that “the e-way bill shall be generated by the principal, wherever required, in case the job worker is unregistered”.

The document. The goods move on a challan issued by the principal under rule 45, with the particulars in rule 55(1). Rule 55(1)(b) names “transportation of goods for job work” as a case for a delivery challan in place of an invoice. Rule 55(3) requires that challan to be “declared as specified in rule 138”. On the portal, the outward sub-type is “Job Work” and the return leg is “Job Work Returns”, each against a delivery challan.

Circular 38 (paragraph 8.4) also sets out the challan practice:

• the principal prepares the challan in triplicate and sends two copies with the goods
• between job workers, the challan may be the principal’s, the job worker’s, or the principal’s endorsed by the job worker
• for goods returning “in piecemeal quantities”, the job worker issues a fresh challan

Goods Sent for Job Work: ITC-04 covers the challan register and the reporting.

The value on the return leg. The return leg can be argued over. The Calcutta High Court’s decision in Gopal Nondy (13 June 2024), discussed in E-Way Bills: When One Is Needed, arose on goods coming back from a job worker. The court remanded the case on whether consignment value under Explanation 2 is the value of the principal’s goods or the job-work charge, determined under section 15.

Bill to one party, ship to another

In a bill-to-ship-to transaction, A orders goods from B and tells B to deliver straight to A’s customer, C. The Ministry of Finance clarified the e-way bill position in a press release of 23 April 2018. It noted that “two supplies are involved and accordingly two tax invoices are required to be issued”: invoice 1 from B to A, and invoice 2 from A to C. On who generates the bill, it said “either ‘A’ or ‘B’ can generate the e-Way Bill but it may be noted that only one e-Way Bill is required”.

The fields depend on who generates it.

Field in Part A	If B generates	If A generates
Bill From	B	A
Dispatch From	B’s principal or additional place of business	B’s principal or additional place of business
Bill To	A	C
Ship To	address of C	address of C
Invoice details	invoice 1 (B to A)	invoice 2 (A to C)

On the portal, the generator selects the transaction type “Bill To – Ship To”. The FAQ explains how the tax heads are entered: “if the Bill to location is inter-state for the supplier, IGST is entered and if the Bill to Party location is intra-state for the supplier, the SGST and CGST are entered irrespective of movement of goods”. The mirror case, “Bill From – Dispatch From”, covers a supplier who bills from its own premises but ships from a third party’s. A fourth type combines the two.

Courts have relied on the e-way bill’s own disclosure of the arrangement.

• Piyush Steel v. State of Gujarat (Gujarat High Court, 18 December 2020). A Bhavnagar trader bought TMT bars from a Jalna supplier and had them shipped straight to its Ahmedabad customer. Both the Jalna supplier and the trader generated documents, and the trader’s bill was marked “bill to ship to” with dispatch from Jalna. The goods were detained for a “mismatch” between the Bhavnagar invoice and the Jalna dispatch point. When the court called for instructions, the State told it that inquiry had shown “no contravention”, and the goods were released.
• Sleevco Traders v. Additional Commissioner (Allahabad High Court, Writ Tax No. 464 of 2021, judgment of 17 May 2022). A Thane supplier’s invoice and e-way bill named the petitioner as buyer and its customer in Sandila, U.P., as ship-to. The goods were detained at Kanpur because the petitioner’s own invoice to the customer had no e-way bill. The court held that once the supplier’s bill showed the ultimate destination and remained valid, “there cannot be any violation”. It quashed the order with costs.
• Kompress India Pvt Ltd v. Union of India (Madras High Court, Madurai Bench, 1 August 2023). A compactor travelled from Navi Mumbai to a storage site of the buyer in Thiruvananthapuram, under invoice and e-way bill. It was detained on the ground that the ship-to address was not a registered place of the buyer. The court held that registration of the buyer’s premises is not the supplier’s obligation. It found the detention contrary to Circular No. 64/38/2018-GST where a valid invoice and bill accompanied the goods, and quashed the order.

A proposed change, now on hold. GSTN advisories of 9 and 17 June 2026 would have made the ship-to GSTIN mandatory on bill-to-ship-to bills and locked ship-to details carried over from the IRN, from 1 August 2026. On 29 July 2026 GSTN announced that implementation “has been kept on hold until further notice”, that “no changes are required to be implemented”, and that the advisories and FAQs would be withdrawn.

SKD, CKD and goods sent in lots

Rule 55(5) governs goods “transported in a semi knocked down or completely knocked down condition or in batches or lots”. The words “or in batches or lots” were inserted by Notification No. 39/2018-Central Tax from 4 September 2018. The rule requires the following.

• The supplier issues “the complete invoice before dispatch of the first consignment”.
• The supplier issues “a delivery challan for each of the subsequent consignments, giving reference of the invoice”.
• Each consignment travels with its delivery challan “along with a duly certified copy of the invoice”.
• The “original copy of the invoice shall be sent along with the last consignment”.

The portal’s FAQ says that “multiple EWBs are required to be generated”, one for each consignment, “based on the delivery challan details along with the corresponding vehicle number”. The sub-type is “SKD/CKD/Lots”, and EWB-01 has a matching reason code (4).

Exports and imports

The portal’s FAQ treats both as requiring a bill: “For imports, the e-way bill will be generated by the importer. The exporter is liable to generate the e-way bill for export supplies.”

• Export. The Bill To party is “URP or GSTIN of SEZ Unit with state as ‘Other Country’”. The ship-to address and PIN are those of the port, airport or border post where the goods leave India.
• Import. The Bill From party is URP with state “Other Country”, and the dispatch address is the point of entry. The second proviso to rule 138A(1) requires the person in charge to carry the bill of entry, and the bill’s number and date go into Part A.
• Distance is counted only within India, from the consignor to the exit point, or from the entry point to the destination.

Rule 138(14) exempts several customs movements:

• clause ©: from a port, airport, air cargo complex or land customs station to an ICD or CFS for clearance
• clause (h): goods under customs bond between an ICD or CFS and a customs station, and goods “under customs supervision or under customs seal”
• clause (i): transit cargo to or from Nepal or Bhutan

Goods sent abroad for exhibition or on consignment. Under Circular No. 108/27/2019-GST (18 July 2019), merely sending such goods out of India “is not a supply”. The goods “shall be accompanied with a delivery challan issued in accordance with the provisions contained in rule 55”. The inland leg to the exit point follows the ordinary e-way bill rules.

Rail, air and ship

• Part B timing. Under rule 138(2A), the supplier or recipient may fill Part B “either before or after the commencement of movement”. For rail, the proviso adds that “the railways shall not deliver the goods unless the e-way bill required under these rules is produced at the time of delivery”. Circular No. 47/21/2018-GST confirms this.
• No copy carried. The proviso to rule 138A(1) dispenses with carrying the e-way bill for movement by rail, air or vessel. The invoice or challan must still travel.
• Railway receipts are validated. The portal now checks railway receipt numbers against the railways’ FOIS and PMS systems (GSTN advisories of 4 October and 18 December 2024). An invalid RR number blocks generation. The FAQ excludes the “leasing of parcel space by Railways” from “transported by railways”.
• Ships take the slower validity. Rule 138(10) gives a multimodal shipment “in which at least one leg involves transport by ship” the ODC rate of one day per 20 km. On the portal, the mode “Ship / Road cum Ship” requires vehicle type ODC.

Multiple vehicles and trans-shipment

Where goods move from one conveyance to another, rule 138(5) requires Part B to be updated “before such transfer and further movement”. The FAQ gives a Cochin-to-Chandigarh example. The bill is updated at each stage: road to the shipyard, ship to Mumbai, road to the airport, air to Delhi, then road. At any time “the details of conveyance specified in the e-way bill … should match” the conveyance actually used.

One consignment split across vehicles. Some consignments arrive at a hub in one large vehicle and must go on in several smaller ones, for example in hilly terrain. For these, the manual describes a “Change to Multi Vehicle” option. The user declares the change, the quantity to be carried, and then each vehicle in turn. The total “cannot exceed quantity mentioned” in the bill. The FAQ says the facility can be used only after Part B has first been updated.

Trans-shipment and delay. Trans-shipment is expressly an “exceptional” circumstance allowing extension under the second proviso to rule 138(10). Transporters routing many bills through branches can consolidate them in EWB-02 at each branch.

Storage in the transporter’s godown. Under Circular No. 61/35/2018-GST (4 September 2018), goods “stored in the transporter’s godown (even if the godown is located in the recipient taxpayer’s city/town) prior to delivery shall always be accompanied by a valid e-way bill”. The recipient may instead declare the godown as an additional place of business, “with the concurrence of the transporter in the said declaration”. The bill is then “deemed to be concluded once the goods have reached the transporter’s godown”. A fresh bill is needed for onward movement from there.

Exhibitions, approval, line sales and own use

None of these is a supply when the goods leave, so the document is a delivery challan under rule 55(1)© (“transportation of goods for reasons other than by way of supply”). The e-way bill follows the threshold in rule 138(1)(ii).

• Exhibitions and fairs. The portal sub-type “Exhibition or Fairs” uses a delivery challan with the generator as both consignor and consignee (“Self”).
• Goods on approval. Circular No. 10/10/2017-GST (18 October 2017) clarifies that goods taken for supply on approval “can be moved from the place of business of the registered supplier to another place within the same State or to a place outside the State on a delivery challan along with the e-way bill wherever applicable”. The invoice is issued “at the time of delivery”. The person carrying the goods “can carry the invoice book”. Where goods carried from one State are sold in another, the supply is inter-State and attracts IGST.
• Line sales and recipient not known. These portal sub-types cover vans selling at customers’ doors. The portal’s earlier FAQ document treats an FMCG truck supplying kirana stores as “movement … caused on behalf of self”, made on a delivery challan. The manual caps line-sales distance at 300 km.
• Own use. Transfers between the generator’s own places use the “For Own Use” sub-type.

Movement of rigs, tools, spares and goods on wheels between distinct persons in different States is treated as neither a supply of goods nor of services by Circular No. 21/21/2017-GST, unless the goods move for further supply. The circular deals with IGST, not with e-way bills. Such movement is still a movement “for reasons other than supply” under rule 138(1)(ii).

Unregistered persons and transporters

Unregistered suppliers and recipients. The e-way bill shows “URP” where a party has no GSTIN. Where a registered recipient buys from an unregistered supplier and is known at the start, the recipient causes the movement and generates the bill (Explanation 1 to rule 138(3)). Where the movement is caused by an unregistered person, the second proviso to rule 138(3) makes generation optional for that person or the transporter.

Enrolment in ENR-03. Notification No. 12/2024-Central Tax inserted a fifth proviso to rule 138(3), brought into force from 11 February 2025 by Notification No. 09/2025-Central Tax. An unregistered person who must generate a bill, or who opts to, “shall submit the details electronically on the common portal in FORM GST ENR-03” and receives “a unique enrolment number”. GSTN’s advisory of 15 February 2025 describes the procedure. On the portal’s Registration menu, the person:

1. selects the State and enters PAN details, which are verified
2. chooses the type (unregistered supplier, unregistered recipient, or both) and enters the address
3. verifies the mobile number by OTP
4. creates a username and password

A 15-character enrolment ID is then issued and is “auto-populated as the Supplier/Recipient” when that person generates a bill.

Handicrafts. Under the fourth proviso to rule 138(1), a person “exempted from the requirement of obtaining registration under clauses (i) and (ii) of section 24” must generate a bill for inter-State movement of handicraft goods “irrespective of the value of the consignment”. “Handicraft goods” take their meaning from Notification No. 56/2018-Central Tax (Explanation 1 to the rule).

Unregistered transporters: ENR-01. A transporter not registered under GST enrols in FORM GST ENR-01 under rule 58(1), the form “only for un-registered persons” under section 35(2). It receives a 15-digit transporter ID, which the FAQ calls TRANSIN, built from the State code and PAN. The portal’s enrolment validates the PAN against the income-tax database and asks for proof of address and identity. The transporter shares the ID with clients, who enter it in the bill to assign Part B to it.

Transporters registered in several States: ENR-02. Under rule 58(1A), a transporter with GSTINs in more than one State under the same PAN may obtain a common enrolment number in FORM GST ENR-02. The proviso then bars it from using “any of the Goods and Services Tax Identification Numbers” for e-way bill purposes. The portal’s FAQ adds that clients “will not be able to update your GSTIN as Transporter Id”.

Citizens. The portal also allows a person with no business registration to enrol as a citizen and generate a bill for goods moved for personal use. The FAQ gives a consumer collecting goods worth more than Rs 50,000 as an example.

What to have ready

Case	Documents	Portal setting
Job work	Rule 45/55 challan in triplicate; ITC-04 register	Outward “Job Work” / inward “Job Work Returns”
Bill-to-ship-to	Both invoices; generator’s invoice in Part A	Transaction type “Bill To – Ship To”
SKD/CKD/lots	Complete invoice before first dispatch; challan per lot; certified invoice copy	Sub-type “SKD/CKD/Lots”, one bill per lot
Export / import	Invoice; shipping bill or bill of entry	“Export” / “Import”, “Other Country”
Rail / air / ship	Railway receipt, airway bill or bill of lading	Mode rail, air or ship; ODC for ship
Exhibition / approval / line sales	Rule 55 delivery challan; invoice book	Matching sub-type; “Self”
Unregistered party	Party’s address and PIN; ENR-03 ID if enrolled	“URP” or enrolment ID

Getting it wrong

The consequences are the same as for any movement: detention under section 129 where goods move in contravention of the rules, and the penalties in section 122 and section 125. Circular No. 64/38/2018-GST lists clerical errors that should attract only a small penalty under section 125 rather than detention. Goods in Transit: Inspection, Detention and Release explains them. In the special cases, the errors that most often lead to detention are a wrong transaction type, a missing challan for a lot, Part B not updated after trans-shipment, and storage beyond validity in a transporter’s godown that has not been declared.

The procedure in summary

1. For inter-State job work, generate the bill whatever the value: the principal does so, or the job worker if registered. Use a rule 45/55 challan and the Job Work sub-types.
2. For bill-to-ship-to, generate one bill only, by A or B, with the matching invoice and the Bill To and Ship To fields set as in the April 2018 clarification.
3. For SKD, CKD or lots, issue the full invoice first, then one challan and one bill for each lot, with the original invoice on the last lot.
4. For exports and imports, show the other party as “Other Country”, count distance within India only, and carry the bill of entry for imports.
5. For rail, air and ship, fill Part B before or after movement. Railways will not deliver without the bill, and ship legs take the ODC validity.
6. Update Part B before every change of vehicle, use the multi-vehicle option to split a consignment, and declare a transporter’s godown as an additional place before using it for storage.
7. Move exhibition, approval, line-sales and own-use goods on a delivery challan with the matching sub-type.
8. Have unregistered parties use URP or enrol in ENR-03. Have unregistered transporters enrol in ENR-01, and transporters registered in several States choose ENR-02 if they want one common ID.

The next guide covers what happens when goods are stopped in transit: inspection, detention and release under section 129.