The truck broke down mid-route and the goods moved to another vehicle
What rule 138(5) and 138(5A) of the CGST Rules require when goods move to a different vehicle mid-route: who updates Part B, when, and what happens to validity.
CA Harun Raaj
pvtltd.co
A breakdown, a transhipment at a godown, a driver who cannot go further: the goods keep moving, on a different vehicle from the one on the e-way bill. Rule 138 answers this directly. It says who must change the conveyance details and when, and it separately says what happens to the bill's validity.
What to do now
- Next step: before the goods are loaded onto the new vehicle, the consignor or the recipient who furnished Part A, or the transporter, must update the conveyance details in Part B of FORM GST EWB-01 on the common portal (rule 138(5)).
- Deadline: "before such transfer and further movement of goods" (rule 138(5)). If the trip may now overrun the bill, note the outer limit in the third proviso to rule 138(10): validity "may be extended within eight hours from the time of its expiry".
- Consequence of not updating: the rule says the person "shall" update before the transfer (rule 138(5)); and for road movement the e-way bill "shall not be valid ... unless the information in Part-B of FORM GST EWB-01 has been furnished" (Explanation 2 to rule 138(3)).
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The rule in one sub-rule
Rule 138(5) covers transhipment directly: "Where the goods are transferred from one conveyance to another, the consignor or the recipient, who has provided information in Part A of the FORM GST EWB-01, or the transporter shall, before such transfer and further movement of goods, update the details of conveyance in the e-way bill on the common portal in Part B of FORM GST EWB-01."
Four things are settled by that sentence.
Who may do it. The consignor or the recipient who provided the Part A information, or the transporter. The rule names the parties who put the information in.
When. "Before such transfer and further movement of goods." The update precedes the movement on the new vehicle.
What changes. The details of conveyance, in Part B of FORM GST EWB-01.
Where. On the common portal.
The two provisions that catch people out
The short final leg. The proviso to rule 138(5): "Provided that where the goods are transported for a distance of upto fifty kilometers within the State or Union territory from the place of business of the transporter finally to the place of business of the consignee, the details of the conveyance may not be updated in the e-way bill." Every condition matters: the last leg, up to fifty kilometres, within the same State or Union territory, from the transporter's place of business to the consignee's. It is a relaxation for that leg. It is not a licence to run the main carriage on an unrecorded vehicle.
The handover to another transporter. Rule 138(5A) allows the bill to be assigned onward: "The consignor or the recipient, who has furnished the information in Part A of FORM GST EWB-01, or the transporter, may assign the e-way bill number to another registered or enrolled transporter for updating the information in Part B of FORM GST EWB -01 for further movement of the consignment". That is how a relay works: the bill carries over to the next transporter, who records the conveyance.
The assignment has a hard stop in the proviso to rule 138(5A): after the details of the conveyance have been updated by the transporter in Part B, the consignor or recipient who furnished Part A is not allowed to assign the e-way bill number to another transporter. Once the transporter has updated Part B, the Part A party cannot reassign the bill.
Who can see the bill, and therefore who can act
Rule 138(4) puts the bill in front of all three parties: "Upon generation of the e-way bill on the common portal, a unique e-way bill number (EBN) shall be made available to the supplier, the recipient and the transporter on the common portal." Because they can all see it, any of the parties named in rule 138(5) can make the update without waiting for the others. If the transporter holds the trip, the transporter can update Part B. If the transporter cannot be reached, the Part A party named in rule 138(5) can make the change, until the transporter has updated Part B and the proviso to rule 138(5A) takes the reassignment away.
The clock, with a worked example
Take a 620 km consignment. Under rule 138(10) the Table gives one day up to 200 km and one additional day for every 200 km or part thereof thereafter (cases other than Over Dimensional Cargo). The remaining 420 km is two full blocks of 200 km plus a part block of 20 km, so three additional days: four days in all.
Explanation 1 to rule 138(10) fixes the count: validity is counted from the time of generation, and "each day shall be counted as the period expiring at midnight of the day immediately following the date of generation of e-way bill". Check the expiry shown on the portal for your bill.
Now suppose the truck breaks down on day two and the goods are transhipped. Updating the conveyance in Part B is required before the transfer (rule 138(5)). The change of vehicle does not by itself extend validity; validity is computed from generation on the distance Table. What the transhipment consumes is time. A two-day wait for a replacement vehicle uses up half of a four-day bill for a journey that was planned to take four.
If the delay means the goods cannot be transported within validity, the second proviso to rule 138(10) applies: "where, under circumstances of an exceptional nature, including trans-shipment, the goods cannot be transported within the validity period of the e-way bill, the transporter may extend the validity period after updating the details in Part B of FORM GST EWB-01, if required." The third proviso adds: "the validity of the e-way bill may be extended within eight hours from the time of its expiry." Do the arithmetic before the second vehicle is loaded, not after.
How long Part B stays updatable
The second proviso to rule 138(9) sets the window: "Provided further that the unique number generated under sub-rule (1) shall be valid for a period of fifteen days for updation of Part B of FORM GST EWB-01."
That is longer than the 24 hours allowed for cancellation under rule 138(9) ("within twenty four hours of generation of the e-way bill"). The difference is a common source of confusion: fifteen days is for updating Part B, 24 hours is for cancelling. A bill may be well past cancellation and still be updatable. The updating window is not the same as the rule 138(5) timing: even inside the fifteen days, the conveyance update has to come before the transfer and further movement.
What to do, in order
- Stop the movement before the transfer: the update is to be made "before such transfer and further movement of goods" (rule 138(5)).
- Decide the route: a named party updates the conveyance on the portal, or the bill is assigned to the next transporter under rule 138(5A) so that transporter can update Part B.
- Make the change while the unique number is still valid for Part B updation (second proviso to rule 138(9)).
- Check the remaining validity against the remaining distance (rule 138(10)) before dispatching.
- If validity will not hold, see the second and third provisos to rule 138(10) above.
- Keep the transporter's trip sheet, breakdown intimation or transhipment record. The rule requires the update; the record is what answers questions about the gap between the two vehicles.
What not to do
Do not let the goods move first and update later. Rule 138(5) puts the update before the transfer and further movement.
Do not assume the Part A party can still reassign the bill. After the transporter updates Part B, the proviso to rule 138(5A) bars reassignment.
Do not stretch the fifty-kilometre proviso. It is written for the final leg, from the transporter's place of business to the consignee's, within the State or Union territory.
Do not confuse the fifteen-day Part B window with the 24-hour cancellation window. They sit in different parts of rule 138(9) and do different things.
FAQ
Who is allowed to change the vehicle on an e-way bill? The consignor or the recipient who provided Part A, or the transporter (rule 138(5)).
How long do I have? The update must come before the transfer and further movement (rule 138(5)). The unique number is valid for fifteen days for updation of Part B (rule 138(9)). Validity of the bill itself is a separate calculation (rule 138(10)).
Must the vehicle be updated for the last few kilometres? The proviso to rule 138(5) says the details of conveyance may not be updated for a final leg of up to fifty kilometres within the State or Union territory, from the transporter's place of business to the consignee's.
The consignment is now with a different transporter. Can I hand over the bill? Yes, under rule 138(5A). Once the transporter has updated Part B, the party who furnished Part A is not allowed to assign it to another transporter.
Does changing the vehicle give me more validity? Not by itself. Validity runs from generation on the distance Table in rule 138(10). Where trans-shipment or other exceptional circumstances stop the goods being transported within validity, the second proviso to rule 138(10) lets the transporter extend it.
Rule text quoted from the CGST Rules, rule 138, as amended to November 2025 (current text). General information, not advice on a particular consignment.
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See Also
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