1. What is E-Invoicing under GST?
E-Invoicing does not mean preparing an invoice on a government portal.
Businesses can continue to prepare invoices through their accounting, billing or ERP software. Where e-invoicing is applicable, specified invoice details are reported to the Invoice Registration Portal (IRP).
After validation, the IRP generates an Invoice Reference Number (IRN) and a digitally signed QR Code.
The e-invoicing framework operates primarily through Rule 48(4) of the CGST Rules, 2017, read with the relevant notifications issued by the Government.
2. Who is Required to Generate E-Invoices?
Under Rule 48(4) read with Notification No. 10/2023-Central Tax, e-invoicing applies to notified registered persons whose aggregate turnover exceeded ₹5 crore in any preceding financial year from FY 2017-18 onwards, subject to prescribed exemptions.
The ₹5 crore threshold has been effective from 1 August 2023.
Turnover is PAN-Based, Not GSTIN-Based
For checking e-invoicing applicability, aggregate turnover is considered on an all-India PAN basis.
It broadly includes:
- Taxable supplies
- Exempt supplies
- Exports
- Inter-State supplies
GST and cess are excluded while calculating aggregate turnover.
West Bengal GSTIN turnover: ₹3.20 crore
Odisha GSTIN turnover: ₹2.40 crore
PAN-based aggregate turnover = ₹5.60 crore
The turnover of both GSTINs has to be considered together while checking e-invoicing applicability.
Once Applicable, Always Applicable
A practical way to understand the turnover condition:
“Once applicable, always applicable.”If a taxpayer has crossed the prescribed ₹5 crore aggregate turnover limit in any preceding financial year from FY 2017-18 onwards, a subsequent fall in turnover below ₹5 crore does not, by itself, take the taxpayer outside the e-invoicing requirement.
Example: A business had aggregate turnover of ₹6.20 crore in FY 2023-24, but its turnover fell to ₹3.80 crore in FY 2025-26.
The business will continue to be covered by e-invoicing, subject to the applicable provisions and exemptions, because the prescribed turnover threshold had already been crossed in an earlier relevant financial year.
3. E-Invoicing Turnover Limit – Notification History
The e-invoicing threshold has been reduced progressively over the years.
| Notification | Turnover Threshold | Effective From |
|---|---|---|
| 13/2020-CT | Above ₹500 crore | 1 October 2020 |
| 88/2020-CT | Above ₹100 crore | 1 January 2021 |
| 05/2021-CT | Above ₹50 crore | 1 April 2021 |
| 01/2022-CT | Above ₹20 crore | 1 April 2022 |
| 17/2022-CT | Above ₹10 crore | 1 October 2022 |
| 10/2023-CT | Above ₹5 crore | 1 August 2023 |
The present ₹5 crore threshold was introduced through Notification No. 10/2023-Central Tax dated 10 May 2023.
4. Which Transactions Require E-Invoicing?
Once a taxpayer is covered by the e-invoicing mandate, IRN generation is required only for specified transactions and documents.
| Transaction / Document | E-Invoice |
|---|---|
| B2B taxable supply | Yes |
| Export | Yes |
| Supply to SEZ | Yes |
| Deemed export | Yes |
| GST Debit Note | Yes |
| GST Credit Note | Yes |
| B2C supply | No |
| Bill of Supply | No |
| Delivery / Job Work Challan | No |
| Financial Credit Note | No |
Tax invoices are principally governed by Section 31 of the CGST Act read with Rule 46 of the CGST Rules, while GST credit and debit notes are covered by Section 34 of the CGST Act.
Therefore, crossing the turnover threshold does not mean that an e-invoice has to be generated for every document issued by the business.
B2C Invoice – Separate Dynamic QR Code Requirement
B2C invoices are not covered by the present e-invoicing mandate.
However, taxpayers having aggregate turnover exceeding ₹500 crore may separately be subject to the Dynamic QR Code requirement on B2C invoices, subject to the prescribed conditions and exemptions.
E-Invoice QR Code and B2C Dynamic QR Code are separate compliance requirements.
5. Who is Exempt from E-Invoicing?
Certain categories of registered persons are excluded from the e-invoicing mandate even where their turnover crosses the prescribed threshold.
These include, subject to the applicable provisions:
- Insurance companies
- Banking companies and financial institutions, including NBFCs
- Goods Transport Agencies (GTA)
- Suppliers of passenger transportation services
- Suppliers of admission services to exhibition of cinematograph films in multiplex screens
- SEZ Units
- Government Departments
- Local Authorities
The exemption framework is contained in Notification No. 13/2020-Central Tax, as amended. Government Departments and Local Authorities were specifically excluded through Notification No. 23/2021-Central Tax dated 1 June 2021.
Exemption Applies to the Entity
Where an entity falls within an exempt category, the e-invoicing exemption is for the entity as a whole and is not restricted only to a particular type of supply made by it.
For example, a banking company covered by the exemption does not become liable to generate e-invoices merely because it also makes some supplies of goods.
SEZ Unit vs SEZ Developer
The exemption available to an SEZ Unit should not be confused with an SEZ Developer.
An SEZ Developer is not automatically exempt merely because it operates within the SEZ framework.
6. 30-Day IRP Reporting Restriction – ₹10 Crore+ AATO
The 30-day reporting requirement is different from the ₹5 crore e-invoicing applicability threshold.
Based on the GSTN Advisory dated 5 November 2024, the earlier reporting restriction applicable to taxpayers with AATO of ₹100 crore and above was extended to taxpayers having AATO of ₹10 crore and above, effective from 1 April 2025.
Such taxpayers must report specified documents to the IRP within 30 days from the document date.
The restriction applies to:
- Invoices
- Credit Notes
- Debit Notes
This is an IRP system-based reporting restriction introduced through GSTN advisory. It should not be confused with a separate 30-day statutory provision under Rule 48.
For a document dated 1 April 2025, reporting is permitted up to 30 April 2025.
After the permitted period, the IRP restricts generation of the IRN.
₹5 Crore vs ₹10 Crore — Do Not Confuse the Two
Subject to the prescribed turnover test and exemptions.
For specified documents under the GSTN/IRP reporting restriction.
A taxpayer can therefore be covered by e-invoicing but not be subject to the 30-day reporting restriction.
A taxpayer with AATO of ₹8 crore may be required to generate e-invoices for applicable transactions, but the ₹10 crore+ 30-day IRP restriction does not apply merely because its turnover exceeds ₹5 crore.
7. How Does E-Invoicing Work?
The invoice therefore does not have to be manually prepared on the IRP.
8. Can an E-Invoice Be Cancelled or Amended?
An e-invoice can generally be cancelled on the IRP within 24 hours of IRN generation, subject to the applicable conditions.
However, an e-invoice cannot be amended on the IRP after generation.
What if an E-Way Bill Has Already Been Generated?
Where an active E-Way Bill is linked to the IRN, the E-Way Bill generally needs to be cancelled first before IRN cancellation can be completed, subject to the applicable conditions and time limits.
Where the IRP cancellation window has expired, the transaction may have to be corrected through the appropriate GST document and return treatment, depending on the nature of the error.
Businesses should therefore verify key particulars before generating an IRN, particularly:
- Recipient GSTIN
- Invoice number
- Invoice date
- Taxable value
- GST rate
- Place of supply
- Document type
9. E-Invoice and GSTR-1
One practical benefit of e-invoicing is reduced duplicate reporting.
Relevant details reported to the IRP are transmitted to the GST system for auto-population in GSTR-1.
However, auto-population should not replace reconciliation.
Cancelled invoices, amendments and transactions not covered by e-invoicing should also be reviewed separately.
10. E-Invoice and E-Way Bill – Rule 138
E-Invoice and E-Way Bill are two separate GST compliances.
The E-Way Bill framework is governed by Rule 138 of the CGST Rules.
Where an E-Way Bill is required, information from the e-invoice can facilitate generation of Part A of FORM GST EWB-01. Transportation details required for Part B must still be furnished wherever applicable.
Generating an E-Invoice does not automatically remove the requirement to generate an E-Way Bill.
Applicability of both requirements should be checked independently.
11. What Happens if E-Invoice is Not Generated?
This is where Rule 48(5) of the CGST Rules becomes important.
Where Rule 48(4) applies, an invoice issued otherwise than in the prescribed manner shall not be treated as an invoice.
Failure to comply may also attract applicable penal provisions under the CGST Act, including Section 122, depending on the facts and nature of the default.
Non-compliance can also create practical problems relating to:
- Invoice validity under GST
- Customer ITC documentation
- GSTR-1 reconciliation
- E-Way Bill compliance
- Vendor and customer compliance controls
Businesses covered by e-invoicing should therefore generate the IRN as part of the regular invoicing process rather than treating it as a month-end GST activity.
12. Practical Examples
A manufacturer covered by e-invoicing sells goods worth ₹4 lakh to a GST-registered dealer.
E-Invoice: Required
The individual invoice value does not determine applicability once the supplier is covered by the mandate.
The same manufacturer sells goods to an unregistered retail customer.
E-Invoice: Not required
Any separate Dynamic QR Code requirement should be checked independently.
A taxpayer covered by e-invoicing exports goods to a customer outside India.
E-Invoice: Required
A business crossed the prescribed turnover threshold in an earlier relevant financial year but subsequently reports turnover below ₹5 crore.
E-Invoicing continues to apply, subject to the applicable provisions and exemptions.
A business is covered by e-invoicing and has AATO of ₹8 crore.
It has to generate e-invoices for applicable transactions. However, the ₹10 crore+ 30-day reporting restriction does not apply merely because its turnover exceeds ₹5 crore.
13. Common E-Invoicing Mistakes
Businesses should particularly avoid:
- Checking turnover GSTIN-wise instead of PAN-wise
- Assuming e-invoicing stops when turnover later falls below ₹5 crore
- Confusing the ₹5 crore threshold with the ₹10 crore 30-day restriction
- Generating e-invoices for B2C transactions unnecessarily
- Missing e-invoices for exports or applicable GST debit/credit notes
- Entering an incorrect recipient GSTIN
- Waiting until GSTR-1 filing to generate IRNs
- Assuming an IRN can be freely amended after generation
- Missing the 24-hour cancellation window
- Trying to cancel an IRN while a linked E-Way Bill remains active
- Assuming E-Invoice generation itself completes E-Way Bill compliance
14. Frequently Asked Questions
Is e-invoicing applicable from ₹5 crore turnover?
Under Notification No. 10/2023-Central Tax, the notified threshold applies where aggregate turnover has exceeded ₹5 crore in any preceding financial year from FY 2017-18 onwards, subject to prescribed exemptions.
Is the ₹5 crore limit checked separately for each GSTIN?
No. Aggregate turnover is considered on an all-India PAN basis.
What does “Once applicable, always applicable” mean?
It is a practical way of understanding the turnover test. If the prescribed threshold was crossed in an earlier relevant financial year, a later fall in turnover below ₹5 crore does not, by itself, remove the e-invoicing requirement.
Is e-invoice required for B2C sales?
No. However, the separate Dynamic QR Code requirement may apply to certain taxpayers having aggregate turnover exceeding ₹500 crore.
Is e-invoice required for exports?
Yes. Export invoices of taxpayers covered by the e-invoicing mandate are reportable to the IRP.
Can an e-invoice be cancelled?
Yes. An IRN can generally be cancelled on the IRP within 24 hours of generation, subject to applicable conditions.
Can an e-invoice be amended on the IRP?
No. An e-invoice cannot be amended on the IRP after IRN generation.
What if an E-Way Bill is already linked to the IRN?
Where an active E-Way Bill is linked to the IRN, it generally needs to be cancelled first before proceeding with IRN cancellation, subject to the prescribed conditions.
Does every taxpayer covered by e-invoicing have only 30 days to generate an IRN?
No. The 30-day IRP reporting restriction applies to taxpayers with AATO of ₹10 crore and above. It should not be confused with the ₹5 crore e-invoicing applicability threshold.
Is an invoice valid if e-invoicing is mandatory but IRN is not generated?
Rule 48(5) provides that where Rule 48(4) applies, an invoice issued otherwise than in the prescribed manner shall not be treated as an invoice.
15. Conclusion
For practical e-invoicing compliance, businesses should remember four key points:
Also remember the practical principle: “Once applicable, always applicable.” If the prescribed turnover threshold was crossed in an earlier relevant financial year, a later fall in turnover does not, by itself, take the taxpayer outside e-invoicing.
IRNs should ideally be generated as part of the regular invoicing process, followed by periodic reconciliation with GSTR-1 and E-Way Bill data. This is safer than identifying missing e-invoices at the time of return filing.
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