Every registered person who causes “movement of goods” of consignment value exceeding fifty thousand rupees - (i) in relation to a supply; or (ii) for reasons other than supply; or (iii) due to inward supply from an unregistered person, shall, before commencement of movement, furnish information relating to the said goods in Part A of FORM GST INS-01, electronically, on the common portal. Any transporter transferring goods from one conveyance to another in the course of transit shall, before such transfer and further movement of goods, generate a new e-way bill. Thus every movement may it be from factory place to the place of transporter, or sending goods to job worker or a movement from manufacturers one location to another shall require an e-way bill. This would be burdensome for the supplier because he will have to keep gauge of every movement of goods.

Also, there are rigid timelines regarding e-way bills. If the goods do not reach the destination in time mentioned in the E way bill then the earlier E way bill will expire and a new E way bill will have to be generated. In case of unforeseen circumstances leading to transfer of goods from one vehicle to another will nullify the earlier e-way bill and transporters would have to create a new e-way bill on the GSTN portal before moving ahead.
The entire multi-layered process will require participation by the supplier, the transporter and even the recipient, who have to communicate its acceptance or rejection of the consignment covered by the e-way bill within a very short period. This will cause myriad of inconveniences and cumbersome digital work for small time businessmen.

Further transporters generally belong to a class that is unorganized and is not well versed with digital equipments, thus it will be a challenge to implement this system smoothly.

Also the assessee will be left burdened with generating the E Bills for every single movement of goods. The proposed E-way bills, which will be required for movement of goods will make transport of goods a cumbersome, delayed and pricey affair under the GST regime.