Check both the timing rule and the delivery condition
From 1 November 2026, paragraph 23 of Notification 05/2026–Central Tax adds metro railway to CGST Rule 138(2A) and its proviso. Where an e-way bill is required, the registered supplier or recipient generates it. Rule 138(2A) permits that person to furnish the transport information in Part B of FORM GST EWB-01 before or after the covered metro movement starts. The timing permission concerns Part B; check the separate requirement to furnish Part A before commencement under Rule 138(1), where applicable. The metro railway must not deliver the goods unless the required e-way bill is produced at delivery.
Read the applicable text: Gazette of India, Notification 05/2026–Central Tax, commencement and paragraph 23 GST Council, underlying CGST Rule 138(2A), subject to later amendment.
Test applicability before classifying the movement
Check the goods, consignment, reason for movement and applicable exemptions or jurisdictional provisions. The general Rule 138(1) trigger is consignment value exceeding ₹50,000, with specified exceptions and cases where a bill is required below that amount. Check the applicable rules for the consignment. Establish whether the relevant leg is in fact transport by metro railway. The notification changes the treatment of the specified mode; it does not create a universal rule for every parcel near a metro station or any general exemption from e-way bill requirements.
Assign the issuer and verify Part B
Agree which registered supplier or recipient generates the e-way bill under Rule 138(2A). Match the source invoice or applicable delivery document, consignor and consignee, quantity and actual transport evidence. Keep portal evidence for the actual mode and Part B. The notified amendment is the legal authority; verify the live portal workflow for metro consignments rather than assuming a particular screen, document prefix or validation behaviour.
Control multimodal legs separately
A road leg may have its own Part B and timing rules. Do not carry the metro timing permission backwards to an earlier road pickup or forwards to a road leg after handover. Keep dispatch, mode change, delivery and onward movement separate in the event log, and verify validity and updates for each applicable stage.
Make the delivery check operational
Match the e-way bill evidence to the parcels and the handover point before releasing goods. If a required bill is absent, keep the affected parcels on hold and record why; if the bill or transport details disagree, investigate the mismatch. Verify and log whether a partial release is operationally and legally appropriate rather than assuming a single document covers the whole shipment.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Part B follows the start of the covered metro leg
On assumed facts, a covered metro movement starts at 09:20, Part B is furnished at 09:45 and the required bill is produced at 11:15 delivery. The entry is 25 minutes after start and 90 minutes before delivery. Check the amended mode rule and all other conditions.
Illustrative example 2: Arrival is not permission to release
A required bill has not been produced at a 14:10 handover attempt. It is presented at 14:55, 45 minutes later. Hold until the check is complete; record the actual release time separately.
Illustrative example 3: Reconcile the parcel count
The consignment list contains 18 boxes but only 16 match the documents produced. The two unmatched boxes remain exceptions pending reconciliation, even when the documents for the other boxes are present.
Illustrative example 4: Road leg before metro
A road pickup starts at 07:50 and the metro leg starts at 09:10, 80 minutes later. The road dispatch must be evaluated on its own facts; the later metro start does not set the road compliance clock.
Illustrative example 5: Match consignment totals
Two invoices in a shipment show 32 and 28 cartons. Handover evidence shows 56 cartons instead of the expected 60. Resolve the four-carton difference and verify the affected document coverage before release.
Illustrative example 6: Prevent duplicate completion counts
A dispatch register has 21 metro consignments; one of 19 available acknowledgements duplicates an earlier reference. Assuming each unique acknowledgement matches a different register entry, 18 consignments have acknowledgements and three require follow-up.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify each transport leg | Routing and booking evidence |
| 2 | Check e-way bill applicability | Consignment facts and applicable rule |
| 3 | Confirm the metro leg | Transport document and mode evidence |
| 4 | Assign the registered issuer | Supplier or recipient responsibility log |
| 5 | Match the commercial documents | Invoice or delivery record and goods list |
| 6 | Verify Part B against the leg | Portal record and transport evidence |
| 7 | Review separate road requirements | Road dispatch and update working |
| 8 | Check the required bill at delivery | Delivery evidence and document reference |
| 9 | Hold and reconcile discrepancies | Exception, count and status log |
| 10 | Archive closure evidence | Final handover and outstanding record |
Sixteen practitioner FAQs
1. What changed on 1 November 2026?
Rule 138(2A) and its proviso now expressly include metro railway.
2. Does the amendment make every metro parcel subject to an e-way bill?
No. Determine whether an e-way bill is required on the facts.
3. Who generates a required e-way bill for the covered movement?
The registered supplier or recipient under Rule 138(2A).
4. Which part of the form carries the movement information?
Part B of FORM GST EWB-01.
5. Can Part B be furnished after the covered metro movement starts?
Yes, for the Part B transport information for that mode, subject to production of the required bill at delivery. Check the separate Part A requirement.
6. May the metro railway deliver if the required bill has not been produced?
No. Apply the delivery proviso.
7. Does the same timing automatically apply to road pickup?
No. Check the road leg under its applicable provisions.
8. What if the goods never travel by metro railway?
Use the rules for the actual movement mode.
9. Can a booking confirmation stand in for the required e-way bill?
No. Preserve and produce the required evidence separately.
10. Does the amendment prescribe a new metro portal prefix?
Do not infer a specific interface or field format from the amendment.
11. What if portal data differs from the parcel count?
Hold the affected items and reconcile the underlying facts.
12. Does producing the bill waive an incorrect mode entry?
No. Verify and correct the discrepancy through the applicable process.
13. Is arrival the same as delivery?
Keep arrival, presentation and actual handover times separately.
14. Can a partial release be assumed permitted?
No. Check coverage and practical separation before release.
15. Should the supplier and recipient both generate separate bills for the same movement?
Assign responsibility and avoid duplicate records for the same required bill.
16. What should a reviewer ask for first?
The route log, required bill evidence, Part B record and signed handover.
Official sources
Gazette of India, Notification 05/2026–Central Tax, commencement and paragraph 23 GST Council, underlying CGST Rule 138(2A), subject to later amendment Official Gazette original: G.S.R. 919(E), Notification 05/2026–Central Tax