E way bill for Public transport

[Ashish Diwedi]

My client is distributor of mobile phones in Chennai. He sells mobile phones to retail outlets in Chennai. But all the goods i.e. mobile phones are delivered through public transport like buses or through Metro. Is E way bill required as the Invoice value is more than ₹ 1 lakh? Is yes, how do we mention the Bus number or Metro number in E way bill? Is there any exemption for the same?

[Shilpi Jain]

There is no exemption. If the transport is through a motorized vehicle it will have to be generated. So transport by metro may not be covered. Otherwise Looks like a practical difficulty in generating EWB. Can explore generating post or during travel.

[ABHISHEK TRIPATHI]

Dear Sh. Dinesh Shah Ji,

The bus being public conveyance under Rule 138(2), last time I had the same query with no answers regarding how to fill vehicle details. Thought of making representation to the government but couldn’t do that. Sir, you need to generate E-way Bill but Part B remains the issue.

Don’t follow: Best possible solution, generate E-way Bill and fill Part A (as the law requires you to generate E-way Bill before the commencement of movement). Get on the bus, fill Part B manually along with the time (the moment you fill in the vehicle details, the E-way Bill becomes valid as per explanation 2). It shouldn’t be like this, but what other options do we have?

Regarding the metro, it runs on a motor, so 138(14) is out of the question. Interestingly, road or railways situation is contemplated by rule 138, they haven't contemplated situation like metro (though a public conveyance but runs on rail, not road). So, if you walk (non-motorised) till the metro station and thereafter from the destination metro station walk (or take cycle, cycle-rickshaw, bullock cart, horse and the likes of NMC) to the place of the recipient then no need to generate E-way Bill. And during the entire journey if the employee takes tempo, then you will face the wrath of 129.

Fun query :)

AI Summary

E-way bill obligation: motorised public transport deliveries require e-way generation, with vehicle details completed when known.
E-way bill obligation applies where goods move in a motorised conveyance; consignors must generate the e-way bill before movement and complete Part A, while Part B (vehicle details) may be entered when the vehicle is known during transit to validate the document. Metro movements present a distinct compliance issue because rail-based public transport may not align with the rule framework for road conveyances; non-motorised legs of a journey do not attract the e-way requirement.