A statutory auditor checking e-way bill compliance tests whether every consignment of goods above the prescribed value threshold moved with a valid e-way bill generated before the movement began, whether the vehicle and transporter details recorded match actual dispatch records, and whether the e-way bill's validity period was consistent with the distance and mode of transport, by reconciling the e-way bill register against the sales and purchase registers and the transport or logistics records, rather than treating e-way bill compliance as a separate paperwork exercise from the goods movement itself; the exact threshold and validity rules should be confirmed against the current GST rules.
Why this is tested separately from GST turnover reconciliation
GSTR-1 and GSTR-3B reconciliation confirm that a supply was reported for tax purposes. The e-way bill confirms that the goods physically moved, when they moved, and by what mode of transport. A sale can be correctly reported for GST and still have an e-way bill that was never generated, generated after the goods left, or generated for the wrong value, each of which is a separate compliance failure with its own penalty exposure.
Testing approach
- 01Confirm threshold applicability by transaction, not by annual turnoverThe e-way bill requirement is triggered by the consignment value of an individual movement, subject to state-specific variations for intra-state movement, not by the company's annual turnover; test a sample of dispatches against the applicable threshold for that state and movement type.
- 02Reconcile the e-way bill register against the sales and purchase registersEvery invoice above the threshold should have a corresponding e-way bill; list invoices without one, and separately list e-way bills without a corresponding invoice, since both directions reveal different gaps.
- 03Check the time sequence between e-way bill generation and dispatchAn e-way bill is required before the commencement of movement; an e-way bill generated after the recorded dispatch time or the invoice time indicates goods moved without one and the bill was generated to retroactively cover it.
- 04Recompute validity period against distanceValidity is driven by the distance declared and the mode of transport; check a sample for goods received or delivered after the e-way bill's validity expired, which is a separate exception from non-generation.
- 05Cross-check vehicle number and transporter ID against actual logistics recordsCompare the vehicle number on the e-way bill to the goods receipt note, weighbridge slip or transporter's own trip record; a mismatch suggests the e-way bill does not reflect the actual movement.
Multi-branch or multi-vehicle stock transfers between locations of the same entity under one GSTIN still generally require an e-way bill for movement of goods even though no sale or GST liability arises; this is a common gap since it is easy to assume e-way bill requirements track GST liability one-to-one.
Regulatory requirement
The exact consignment value threshold, state-specific variations for intra-state movement, validity period formula, and the documents required to accompany a shipment are set out in the GST Act and rules as currently in force. Confirm all of these against current source material before concluding on compliance.
This is practical guidance written for audit teams, not an authoritative statement of any standard or statute. Standards, forms and timelines change. Check the current text issued by the ICAI and the relevant authority before relying on anything here in an audit file.
Related resources
- Revenue, receivables & cut-offExport sales audit checklist: FIRC, shipping bill and GSTThe documents unique to export sales, how to test realisation of export proceeds, and how the GST refund process interacts with export audit work.
- Audit data & extractsConsolidating multi-branch data for a single auditSeparate company files per branch, inter-branch transfers that need eliminating, and vendors shared across branches that look like duplicates. Consolidating multi-branch data before testing starts.
- Purchase & AP auditGoods receipt note (GRN) audit and the missing-GRN riskWhat to test when a client's GRNs do not exist or cannot be trusted, and how GRN-to-invoice timing is used as a cut-off indicator rather than a formality.
- Revenue, receivables & cut-offSales cut-off testing: dispatch, invoice and ledger datesWhy dispatch, invoice and ledger dates disagree at year end, how to sample either side of the cut-off, and the evidence that settles which date governs.
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