Identify whose response the rule expects
CGST Rule 138(11) makes e-way bill details available to the registered supplier if Part A of EWB-01 was furnished by the recipient or transporter, or to the registered recipient if Part A was furnished by the supplier or transporter. The supplier or recipient, as applicable, communicates acceptance or rejection of the consignment. Where the transporter furnished Part A, check availability for each relevant registered GSTIN under the respective clause. Do not assign every decision to accounts payable by default.
Read the applicable text: CBIC: CGST Rule 138(11) and (12) Official e-way bill portal: Chapter XVI rules.
Measure two timestamps and use the earlier
Rule 138(12) deems the details accepted if the party does not communicate acceptance or rejection by the earlier of 72 hours after the details are made available on the portal and delivery of the goods. Record availability, delivery and the communication separately. The portal FAQ describes the 72 hours by reference to generation. Use the rule’s wording: count from when the details were made available to the relevant party on the common portal, and compare with actual delivery. Neither invoice date nor the e-way bill validity clock is a substitute.
Check the discrepancy before delivery shortens the window
Compare the purchase or sale record, tax document, GSTIN, quantities and actual movement. Assign the review to someone who can act before the earlier cut-off. If a party disputes the data, the NIC portal guidance describes using Reject to find bills generated by others against that GSTIN. Preserve the submitted response and timestamp. If the deadline already passed, retain the portal status and physical facts and review the appropriate next steps under the actual circumstances.
Keep the deeming rule in its lane
The rule deems acceptance of the e-way bill details. It does not itself prove delivery, decide contract acceptance, cure incorrect tax documents or establish entitlement to input tax credit. Keep physical delivery, invoice reconciliation and any correction under their separate requirements. For staggered delivery, retain each event and establish the operative delivery facts rather than assuming the last internal posting controls.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Delivery cuts the window short
Details become available at 10:00 on 7 November. The 72-hour endpoint is 10:00 on 10 November. Delivery at 15:00 on 8 November is earlier, 29 hours after availability.
Illustrative example 2: Seventy-two hours comes first
Availability is 17:30 on 7 November and delivery is 08:00 on 11 November. The cut-off is 17:30 on 10 November, 14 hours 30 minutes before delivery.
Illustrative example 3: Earlier than delivery but late under the rule
Availability is 09:00 on 5 November, delivery is 18:00 on 8 November, and the proposed response is 10:15 on 8 November. It is 75 minutes after the 09:00 cut-off despite preceding delivery.
Illustrative example 4: Generation is not the assumed availability time
Assume generation at 07:00 on 7 November, portal availability at 12:00, and no earlier delivery. The 72-hour endpoint is 12:00 on 10 November, five hours later than a generation-based calculation.
Illustrative example 5: Express rejection before delivery
Availability is 11:00 on 7 November; delivery is scheduled and occurs at 11:00 on 8 November. A rejection submitted at 09:30 on 8 November precedes that cut-off by 90 minutes.
Illustrative example 6: Cross month-end
Details are made available at 22:15 on 30 November and delivery is at 06:15 on 3 December. The 72-hour endpoint is 22:15 on 3 December, but delivery controls, 56 hours after availability.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Record the e-way bill and relevant GSTINs | EWB-01 details and transaction master |
| 2 | Identify who furnished Part A | Portal and transport documentation |
| 3 | Identify the registered response party | Rule 138(11) role check |
| 4 | Record actual portal availability | Timestamped evidence |
| 5 | Record expected and actual delivery | Dispatch plan and proof of delivery |
| 6 | Compare the two cut-offs | 72-hour and delivery working |
| 7 | Verify the document and shipment details | Invoice, order and movement comparison |
| 8 | Capture the response and exact time | Submitted communication evidence |
| 9 | Reconcile deemed status with the physical facts | Delivery and discrepancy file |
| 10 | Review separate correction and ITC requirements | Documented legal and return review |
Sixteen practitioner FAQs
1. Who responds where the supplier furnished Part A?
The registered recipient is the relevant party under clause (b).
2. Who responds where the recipient furnished Part A?
The registered supplier is the relevant party under clause (a).
3. What changes if a transporter furnished Part A?
Both clauses refer to transporter-furnished details. Check availability and the response for each relevant registered party under the respective clause.
4. Does the rule give 72 hours after delivery?
No. Delivery can be the earlier endpoint.
5. Is the 72-hour period expressed in working hours?
No. The rule uses hours without a working-hours qualification.
6. Does an invoice date start the clock?
Use availability of the details on the common portal.
7. Does the e-way bill’s validity expiry decide the response deadline?
No. Apply Rule 138(12) separately.
8. Can a late internal goods receipt posting extend the deadline?
Use the supported delivery time rather than the ERP posting time.
9. What does silence trigger under the rule?
Deemed acceptance of the e-way bill details after the applicable window.
10. Does deemed acceptance establish ITC?
Review the statutory input tax credit conditions independently.
11. Does deemed acceptance prove that goods arrived?
No. Retain separate delivery evidence.
12. What if the invoice and portal show different quantities?
Investigate before the cut-off and preserve the discrepancy and response.
13. What if only part of the load arrives?
Document the actual delivery events and assess the relevant cut-off on those facts.
14. Does emailing the seller substitute for portal communication?
Check the rule and use the common-portal mechanism for the required communication.
15. What if the system time is disputed?
Keep timestamp evidence and a clear comparison of the actual events.
16. Can a user erase the deemed status by updating its ERP?
No. Keep portal and internal records distinct and use only applicable correction mechanisms.
Official sources
CBIC: CGST Rule 138(11) and (12) Official e-way bill portal: Chapter XVI rules Notification 12/2018–Central Tax: Rule 138(11) and (12) NIC e-way bill portal: rejection workflow and operational FAQ