E-invoicing and e-way bills are two different GST obligations that are easy to confuse because both are generated online and both carry a reference number. An e-invoice is about the invoice itself: certain businesses must report each B2B invoice to the government’s Invoice Registration Portal and get an Invoice Reference Number (IRN) on it. An e-way bill is about moving goods: when goods worth more than ₹50,000 travel, a document must be generated before the vehicle leaves.
A business can need one, both or neither. A software consultant above the turnover limit needs e-invoices but never e-way bills. A small trader who ships goods needs e-way bills even though it is far below the e-invoice limit. The sections below take each in turn. If you would rather have your monthly returns handled alongside, our GST return filing service prepares and files GSTR-1 and GSTR-3B for you.
E-invoicing: who has to do it
The legal basis is rule 48(4) of the CGST Rules. It says invoices must be prepared by uploading them to the common portal and obtaining an IRN, for “such class of registered persons as may be notified”. The notified class is set by turnover:
- A registered business whose aggregate turnover exceeded ₹5 crore in any financial year from 2017-18 onwards must issue e-invoices. This limit has applied since 1 August 2023; earlier it was higher and was lowered in steps.
- Aggregate turnover is counted on the PAN, across all GSTINs of the business in every state, not GSTIN by GSTIN.
- Once you cross the limit in any year, you stay in. A later year with lower turnover does not take you out.
E-invoicing covers invoices, credit notes and debit notes issued to registered buyers (B2B) and for exports. Invoices to consumers (B2C) are outside it.
Businesses exempted by class
Some businesses are excluded whatever their turnover. The e-invoice portal’s summary of the notification lists:
- units in a Special Economic Zone;
- insurers, banking companies and financial institutions, including NBFCs;
- goods transport agencies, for the transport of goods by road;
- suppliers of passenger transport services;
- suppliers of admission to cinema screenings in multiplex screens;
- government departments and local authorities.
What happens if you skip it
Rule 48(5) is blunt: an invoice that a notified business issues any other way “shall not be treated as an invoice”. In practice that hurts your customer first. A buyer cannot rely on an invoice without an IRN to claim input tax credit, so expect payment to stall until a valid e-invoice is issued. Penalties for issuing an incorrect invoice can also follow.
GSTN has also introduced time limits for reporting older invoices to the portal for larger businesses. If your turnover is ₹10 crore or more, check the current advisory on the e-invoice portal and report invoices as soon as they are raised.
E-way bills: when moving goods needs one
The e-way bill comes from rule 138 of the CGST Rules. A registered person who causes goods to move must generate one before the movement starts when the consignment value exceeds ₹50,000. That applies whether the movement is:
- for a sale or other supply;
- for a reason other than supply, such as sending goods for job work or moving stock between your own branches;
- an inward supply from an unregistered person.
Below ₹50,000 the e-way bill is optional, though a transporter may still choose to carry one. Some states set a different limit for movement that stays inside the state, so check your state’s notification if your goods do not cross a state border.
Part A, Part B and the 50 km relief
An e-way bill has two parts. Part A holds the invoice and goods details: who is supplying, who is receiving, what the goods are and their value. Part B holds the vehicle or transport document number. Either the supplier, the recipient or the transporter (on authorisation) can fill it in.
Rule 138 relaxes Part B for short first legs. Where goods move up to 50 km within the same state from the consignor’s place of business to the transporter’s, for onward transport, Part B need not be filled for that leg. Part A is still required.
How long an e-way bill lasts
| Distance | Validity (other than over-dimensional cargo) |
|---|---|
| Up to 200 km | One day |
| Each further 200 km or part of it | One more day |
Over-dimensional cargo and some multimodal shipments by ship have their own, longer periods in the same table.
When no e-way bill is needed
Sub-rule (14) of rule 138 lists situations where no e-way bill is required at all. The main ones:
- goods listed in the Annexure to rule 138;
- goods carried by a non-motorised conveyance, such as a hand cart;
- goods moving from a customs port, airport, air cargo complex or land customs station to an inland container depot or container freight station for customs clearance;
- movement within areas a state has notified for this purpose;
- most goods that are exempt from GST under the rate notification.
How the two fit together
For a business that issues e-invoices and also ships goods, the two systems are linked. When the e-invoice is registered, the details already reported can be used to generate the e-way bill, so Part A does not have to be typed in twice. You still add the transport details.
| Question | E-invoice | E-way bill |
|---|---|---|
| What triggers it | Your turnover (above ₹5 crore in any year from 2017-18) | A movement of goods worth more than ₹50,000 |
| Applies to services? | Yes, B2B and exports | No, goods only |
| Generated when | When the invoice is raised | Before the goods start moving |
| Rule | Rule 48(4) | Rule 138 |
Frequently asked questions
We crossed ₹5 crore last year but turnover has fallen. Do we still issue e-invoices?
Yes. The test is turnover in any financial year from 2017-18. Once crossed, the obligation stays.
Do e-invoices replace GSTR-1?
No. E-invoice data is auto-populated into GSTR-1, but you still file GSTR-1 and check it, especially for invoices outside e-invoicing such as B2C sales.
Is an e-way bill needed if we deliver in our own vehicle?
Yes, if the consignment value exceeds ₹50,000 and no exemption applies. The rule turns on the goods and their value, not on who owns the vehicle.
Complianto (complianto.in), operated by Mentorcorp Private Limited, is a private consultancy and is not affiliated with any government body. We do not issue official documents. We charge a professional fee for application assistance and advisory services. Applicants can apply directly to the government without our fees via the official portals: MCA (mca.gov.in), Income Tax (incometax.gov.in), GST (gst.gov.in), MSME (udyamregistration.gov.in), FSSAI (foscos.fssai.gov.in), Startup India (startupindia.gov.in), and IP India (ipindia.gov.in).
This article is general information, not legal or tax advice.
