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Direct and Indirect Taxation · Tax Invoice - Electronic Way Bill

Rule 138A: Documents and Devices to Be Carried in Conveyance

Updated 10 October 2026 · Fact-checked

Rule 138A of the CGST Rules, 2017 says the person in charge of a conveyance must carry the invoice, bill of supply or delivery challan, plus the e-way bill (physical copy, e-way bill number, or RFID-mapped). Rail, air and vessel movement need no e-way bill. Imported goods also need a bill of entry copy.

Understand Rule 138A: Documents and Devices to Be Carried in Conveyance

When goods move on a road, an officer may stop the vehicle and ask what is inside and whether tax has been paid. Section 68 of the CGST Act, 2017 gives the legal base. The Government may require the person in charge of a conveyance carrying goods above a specified value to carry prescribed documents and devices. Rule 138A is where those documents and devices are prescribed.

The person in charge of a conveyance is usually the driver. Under sub-rule (1) he must carry two things: (a) the invoice, bill of supply or delivery challan, as the case may be; and (b) a copy of the e-way bill in physical form, or the e-way bill number in electronic form, or the e-way bill mapped to a Radio Frequency Identification Device (RFID) embedded on the conveyance, in the manner notified by the Commissioner.

There are special cases. The first proviso says clause (b) does not apply where goods move by rail, air or vessel. The second proviso says that for imported goods the person in charge must also carry a copy of the bill of entry filed by the importer, and the number and date of the bill of entry must be shown in Part A of FORM GST EWB-01.

Sub-rule (2) helps e-invoicing. Where the invoice is issued under rule 48(4), the QR code with the embedded Invoice Reference Number (IRN) may be produced electronically for the proper officer instead of a physical copy of the tax invoice. Sub-rule (3) says that where the registered person uploads the invoice, Part A of FORM GST EWB-01 is auto-populated from FORM GST INV-1 data.

Sub-rule (4) lets the Commissioner, by notification, require a class of transporters to get a unique RFID device embedded on the conveyance and map the e-way bill to it before the goods move. Sub-rule (5) lets the Commissioner, where circumstances warrant, require the driver to carry other documents instead of the e-way bill: the tax invoice, bill of supply or bill of entry, or a delivery challan where goods move for reasons other than supply.

Related rules complete the picture. Rule 138B lets the Commissioner (or an officer empowered by him) authorise the proper officer to intercept any conveyance and verify the e-way bill, in physical or electronic form, for inter-State and intra-State movement. Rule 138C governs the inspection report. Rule 55A requires the invoice or bill of supply to be carried where no e-way bill is required.

Key rules to remember

Core documents (Rule 138A(1))
Invoice / bill of supply / delivery challan + e-way bill (physical copy OR number in electronic form OR RFID-mapped)
Both (a) and (b) must be carried. Clause (b) does not apply to movement by rail, air or vessel.
Imported goods (second proviso)
Above documents + copy of bill of entry; number and date in Part A of FORM GST EWB-01
The bill of entry is the one filed by the importer.
E-invoice (Rule 138A(2))
QR code with IRN may be produced electronically in lieu of physical tax invoice
Applies where invoice is issued under rule 48(4).
RFID (Rule 138A(4))
Notified class of transporters: unique RFID embedded on conveyance + e-way bill mapped before movement
Requires a notification by the Commissioner.
Substitute documents (Rule 138A(5))
Tax invoice / bill of supply / bill of entry, or delivery challan for non-supply movement, instead of e-way bill
Only when the Commissioner notifies it, where circumstances warrant.
Interception (Rule 138B)
Commissioner or empowered officer authorises proper officer to intercept any conveyance to verify e-way bill
Covers inter-State and intra-State movement. Physical verification is by the authorised proper officer.
Inspection report (Rule 138C)
Part A of FORM GST EWB-03 within 24 hours; Part B within 3 days
Part B time can be extended by up to 3 more days on sufficient cause. Time counts from midnight of the date of interception.
No repeat verification (Rule 138C(2))
Once physically verified in transit, no further physical verification again
Unless specific information on tax evasion is made available later.

How to solve Rule 138A: Documents and Devices to Be Carried in Conveyance questions

Most questions give a movement of goods and ask what the driver must carry, or whether an officer can act. Use this method.

  1. 1Identify the mode of transport: road, rail, air or vessel. If rail, air or vessel, the e-way bill clause (b) does not apply.
  2. 2List the base documents under sub-rule (1)(a): invoice, bill of supply or delivery challan, matching the nature of the movement.
  3. 3Add the e-way bill under (b): physical copy, e-way bill number electronically, or RFID-mapped, as notified.
  4. 4Check for imports: if goods are imported, add the importer's bill of entry and note its number and date in Part A of FORM GST EWB-01.
  5. 5Check for e-invoice: if issued under rule 48(4), the QR code with IRN can be shown electronically.
  6. 6Check for any notification under sub-rule (4) or (5) requiring RFID or substitute documents.
  7. 7If the question is about interception, apply rule 138B for who can intercept, rule 138C for reports and timelines, and section 68 of the Act for the duty to produce documents.
  8. 8Write the answer in short points, each tied to the sub-rule.

Quickest way: Two-plus-three checklist

When to use it: Use for MCQs and short scenario questions where you have under two minutes.

  1. Remember the base pair: invoice-type document + e-way bill.
  2. Then run three checks: mode (rail, air, vessel), import (bill of entry), e-invoice (QR with IRN).
  3. For inspection timing, recall 24 hours for Part A and 3 days for Part B of FORM GST EWB-03.
  4. Pick the option that matches exactly; reject options that add conditions the rule does not state.

Common mistakes in Rule 138A: Documents and Devices to Be Carried in Conveyance

  • Saying an e-way bill is needed for rail, air or vessel movement under rule 138A(1)(b).

    Students remember the general rule and forget the first proviso.

    Fix: Link the proviso to the three modes: rail, air, vessel. Clause (b) does not apply to them.

  • Forgetting the bill of entry for imported goods.

    The requirement sits in a proviso, not the main text.

    Fix: Whenever the question says imported, add the importer's bill of entry and its number and date in Part A of FORM GST EWB-01.

  • Thinking RFID is compulsory for every vehicle.

    The rule mentions RFID in clause (b) and sub-rule (4), which sounds universal.

    Fix: RFID mapping is one permitted mode, and mandatory only for a class of transporters the Commissioner notifies.

  • Mixing up the Part A and Part B timelines in rule 138C.

    Both are short periods in the same sub-rule.

    Fix: Part A summary: 24 hours. Part B final: 3 days. Extension: up to 3 more days, counted from midnight of the date of interception.

  • Believing a vehicle can be physically verified repeatedly.

    Students assume officers in every State can check again.

    Fix: Rule 138C(2): once verified, no further physical verification unless specific information on evasion is available later.

  • Saying the QR code with IRN replaces the e-way bill.

    Sub-rule (2) mentions electronic production.

    Fix: The QR code with IRN may replace only the physical copy of the tax invoice, not the e-way bill.

Worked examples

Example 1

A truck driver carries machinery from Pune to Nagpur by road for a registered supplier. State the documents and devices the person in charge must carry under rule 138A, assuming no special notification.

Show the solution
  1. Mode is road, so the exemption in the first proviso does not apply.
  2. Under rule 138A(1)(a), he must carry the invoice (or bill of supply or delivery challan as applicable). A tax invoice fits a supply.
  3. Under rule 138A(1)(b), he must carry a copy of the e-way bill in physical form, or the e-way bill number in electronic form, or have it mapped to an RFID device embedded on the conveyance as notified.
  4. The goods are not imported, so no bill of entry is needed.

Answer: He must carry the tax invoice and the e-way bill (physical copy, electronic number, or RFID-mapped). No bill of entry is needed.

Example 2

Goods imported by Sharma Traders are moved by road from the port to its warehouse. Also, an officer intercepts the vehicle and completes inspection on 10 March. State what the driver carries and the time limits for the officer's inspection reports.

Show the solution
  1. Under rule 138A(1), the driver carries the invoice or delivery challan as applicable and the e-way bill in permitted form.
  2. Under the second proviso, since goods are imported, he also carries a copy of the importer's bill of entry. Its number and date appear in Part A of FORM GST EWB-01.
  3. Under rule 138C(1), the officer records the summary report in Part A of FORM GST EWB-03 within 24 hours of inspection and the final report in Part B within 3 days.
  4. The periods count from midnight of the date of interception, per the Explanation.
  5. The Commissioner or an authorised officer may extend the Part B time by up to 3 days on sufficient cause.

Answer: The driver carries the invoice or challan, the e-way bill and the bill of entry copy. The officer records Part A within 24 hours and Part B within 3 days, counted from midnight of the interception date, with a possible extension of up to 3 more days for Part B.

Exam tips

  • Write sub-rule numbers in written answers. Marks follow structure: documents, devices, special cases.
  • MCQs often test provisos: rail, air, vessel exemption, and bill of entry for imports.
  • Quote the Rule 138C timelines exactly: 24 hours and 3 days.
  • Link rule 138A with section 68 of the Act, which gives the legal authority and duty to produce documents.
  • Do not state value limits for the e-way bill here. Those are not part of rule 138A.

Practice questions from Tax Invoice - Electronic Way Bill

Rule 138A: Documents and Devices to Be Carried in Conveyance: frequently asked questions

Who is the person in charge of a conveyance under rule 138A?

It is the person responsible for the vehicle during movement, usually the driver. He must carry the prescribed documents and produce them if the vehicle is intercepted, as section 68 of the CGST Act requires.

Is a physical e-way bill compulsory?

No. Rule 138A(1)(b) allows a physical copy, the e-way bill number in electronic form, or an e-way bill mapped to an RFID device embedded on the conveyance, in the manner notified.

Can the QR code on an e-invoice be shown instead of a paper invoice?

Yes, where the invoice is issued under rule 48(4). The QR code with the embedded IRN may be produced electronically for the proper officer in lieu of the physical tax invoice. It does not replace the e-way bill.

What if no e-way bill is required for the movement?

Rule 55A then requires the person in charge to carry a copy of the tax invoice or bill of supply. Rule 138A deals with cases where the e-way bill is part of the documents.