Electronic Invoicing: Essential Questions and Answers
This article addresses frequently asked questions about e-invoicing under GST in India, a system requiring businesses to report B2B invoices to an Invoice Registration Portal (IRP) for verification and IRN generation. It outlines the phased implementation based on aggregate turnover thresholds, key benefits, and essential compliance rules. The content covers aspects like e-invoice generation deadlines, format requirements, amendment/cancellation procedures, and integration with GST returns and e-way bill systems.
Electronic invoicing, also known as e-invoicing, is a GST system where applicable businesses must submit their B2B invoices to an Invoice Registration Portal (IRP). The GSTN verifies these invoices, issuing a unique Invoice Reference Number (IRN) and a digitally signed QR code in return. The e-invoicing framework began on October 1, 2020, for taxpayers with an aggregate turnover exceeding Rs. 500 crore. Its scope broadened to include businesses with over Rs. 100 crore turnover from January 1, 2021, and then those with a total turnover between Rs. 50 crore and Rs. 100 crore starting April 1, 2021. Subsequently, the government expanded e-invoicing to businesses exceeding Rs. 20 crore turnover from April 1, 2022, and further to those with turnover above Rs. 10 crore from October 1, 2022. Most recently, the CBIC mandated e-invoicing for businesses with over Rs. 5 crore turnover, effective August 1, 2023. The aggregate turnover for e-invoicing considers the combined turnover of all GSTINs associated with a single PAN nationwide. This document provides answers to common questions regarding the e-invoicing system under GST. Records of these discussions are publicly available, often referred to as e-Invoicing FAQs.
Fundamental Aspects of e-Invoicing
What does e-invoicing entail?
Electronic invoicing, or e-Invoicing, is a method of generating invoices that are standardized, allowing different software systems to read them without requiring fresh data entry or manual intervention. Essentially, it ensures data interoperability by creating invoices in a unified, machine-readable format.
What are the regulatory provisions for e-invoicing?
CGST Rule 48 outlines the regulations governing the applicability and creation of e-invoices.
Is there a specific deadline for e-invoice generation?
Prior to October 31, 2023, the GST system did not impose a fixed deadline for e-invoice generation. However, effective November 1, 2023, taxpayers with an Aggregate Annual Turnover (AATO) of Rs. 100 crore or more must generate e-invoices for tax invoices and credit/debit notes within 30 days of the document date. Failure to comply renders these documents non-compliant. This 30-day limit will extend to taxpayers with an AATO of Rs. 10 crore and above from April 1, 2025, as per an advisory issued on November 5, 2024. For other taxpayers, where no specific time limit is defined, it is advisable to generate e-invoices on or after the invoice date but before filing their GSTR-1 returns.
Can e-invoices be issued after the invoice date?
Yes, e-invoices are typically generated after the actual invoice date. Until October 31, 2023, there was no specified time limit. From November 1, 2023, businesses with an AATO of Rs. 100 crore or more must generate e-invoices within 30 days of the invoice date for tax invoices and credit/debit notes. This requirement will apply to taxpayers with an AATO exceeding Rs. 10 crore from April 1, 2025.
Is it permissible to generate e-invoices with a backdate?
No. While there was no time restriction until October 31, 2023, as of November 1, 2023, taxpayers with an AATO of Rs. 100 crore or more must generate e-invoices within 30 days of the invoice date. Issuing e-invoices for previous dates beyond this window will result in non-compliance. For other taxpayers without a defined time limit, it is recommended to create e-invoices on or after the invoice date but before submitting GSTR-1 returns.
Is e-invoicing compulsory, and who is subject to it?
E-invoicing became mandatory for all businesses with an aggregate turnover exceeding Rs. 500 crore in any financial year from 2017-18 to 2019-20, effective October 1, 2020. The mandate expanded to businesses with over Rs. 100 crore turnover from January 1, 2021, and further to those with more than Rs. 50 crore turnover from April 1, 2021. Subsequently, it was extended to businesses with over Rs. 20 crore turnover from April 1, 2022, then to those with over Rs. 10 crore turnover from October 1, 2022, and most recently, to businesses with over Rs. 5 crore turnover from August 1, 2023.
However, certain categories of registered persons are exempt from e-invoicing, irrespective of their turnover, as per CBIC Notification No. 13/2020 – Central Tax:
- Insurers, banking companies, financial institutions, including NBFCs.
- Goods Transport Agencies (GTA).
- Registered persons providing passenger transportation services.
- Registered persons offering services for admission to cinematographic film exhibitions in multiplexes.
- SEZ units (excluded by CBIC Notification No. 61/2020 – Central Tax).
- Government departments and local authorities (excluded by CBIC Notification No. 23/2021 – Central Tax).
- Persons registered under Rule 14 of the CGST Rules (OIDAR).
What advantages does e-invoicing offer?
E-invoicing provides several benefits:
- Simplified Reporting: Invoices are reported once during generation, reducing the need for multiple format submissions.
- Auto-population of Returns: A significant portion of GSTR-1 data can be automatically pre-filled from e-invoices.
- Streamlined E-Way Bill Generation: E-way bills can be easily created using e-invoice data.
- Minimized Reconciliation: Reduces the need for data reconciliation between accounting records and GST returns.
- Real-time Tracking and ITC: Enables real-time tracking of invoices and faster availability of Input Tax Credit, also mitigating ITC verification issues.
- Enhanced Tax Management: Improves the automation and management of the tax filing process.
- Fraud Reduction: Tax authorities gain real-time access to data, reducing the likelihood of fraud.
- Elimination of Fake Invoices: Prevents the generation of fraudulent GST invoices.
Does the e-invoice schema apply to transactions under the Reverse Charge Mechanism (RCM)?
Yes, the e-invoice framework is applicable to reverse charge mechanism (RCM) transactions as specified under Section 9(3).
If a company's turnover surpasses the e-invoicing threshold in November 2022 (FY 2022-23), when should it begin generating e-invoices?
E-invoicing eligibility is determined by the aggregate turnover of preceding financial years, starting from FY 2017-18. If a business exceeds the prescribed limit in a financial year, it must commence e-invoicing from the beginning of the subsequent financial year. For instance, if the threshold was crossed in FY 2022-23, e-invoicing becomes mandatory from April 1, 2023.
Our turnover has surpassed the specified limit in the current financial year. Are we required to upload our invoices?
No. E-invoice applicability is triggered only if the turnover in any previous financial year (from 2017-18 onwards) has exceeded the stipulated threshold.
For e-invoicing eligibility, aggregate turnover is considered from FY 2017-18 onwards. Given that GST was implemented on July 1, 2017, should the aggregate turnover for FY 2017-18 be calculated from April 1, 2017, or July 1, 2017?
The aggregate turnover for e-invoicing purposes is calculated according to the definition in Section 2(6) of the Central Goods and Services Tax (CGST) Act. For FY 2017-18, this calculation should cover the period from July 1, 2017, to March 31, 2018.
Which types of supplies are currently covered under e-invoicing?
E-invoicing currently applies to:
- Supplies made to registered persons (B2B supplies).
- Supplies to SEZ developers (with or without tax payment).
- Exports (with or without tax payment).
- Deemed exports.
These provisions apply to specific classes of notified taxpayers. It does not extend to Free Trade & Warehousing Zones (FTWZ), import transactions, input service distributors, high sea sales, or bonded warehouse sales. The exemption is entity-specific, not transaction-specific.
Is e-invoicing applicable to nil-rated or wholly-exempt supplies?
No, e-invoicing does not apply to nil-rated or wholly-exempt supplies. For these cases, only a bill of supply is issued, not a tax invoice.
Is e-invoicing required for invoices exchanged between two different GSTINs under the same PAN?
Yes, for specifically notified persons, e-invoicing is compulsory for supplies of goods or services (or both) to a registered person, even if they fall under the same PAN but different GSTINs.
Is it necessary to generate an e-invoice for the export of services?
Yes, e-invoices must be generated for all export transactions that are B2B in nature.
Are financial or commercial credit notes required to be reported to the IRP?
No, only credit and debit notes issued under Section 34 of the CGST or SGST Acts must be reported to the IRP.
Is there a time limit for issuing a credit note against an e-invoice?
There is no defined time limit for issuing a credit or debit note against an e-invoice. However, from November 1, 2023, taxpayers with an AATO of Rs. 100 crore and above must report tax invoices, debit notes, and credit notes to the IRP within 30 days of the document date; failure to do so will result in non-compliant documents.
Can the traditional invoice be used in conjunction with the e-invoice portal-generated e-invoice? Can the traditional invoice be issued to the buyer instead of the portal-generated one?
The invoice issued to the customer must include the IRN and the QR Code. You may also send the traditional invoice along with it. However, the legally valid document for compliance is the e-invoice containing the IRN and QR code.
The E-Invoicing Process Flow
How does the e-invoicing model operate?
In the e-invoicing model, businesses continue to generate invoices using their existing ERP systems. The key change is the specification of a standard schema and format for invoices, ensuring standardization and machine-readability. The taxpayer remains responsible for generating the invoice.
Upon generation, the invoice must be reported to the GST Invoice Registration Portal (IRP). The IRP then generates a unique Invoice Reference Number (IRN), digitally signs the e-invoice, and embeds a QR code. This QR code contains critical e-invoice parameters. The IRP returns the signed e-invoice to the taxpayer and also sends it to the seller's registered email address.
What is the workflow for an e-invoice?
An e-invoice workflow involves two primary interactions. First, the business/supplier interacts with the Invoice Registration Portal (IRP). The supplier generates an invoice and uploads its JSON file to the IRP. The IRP validates the data, generates an IRN and QR code, digitally signs the invoice, and then returns it to the supplier.
Second, the IRP interacts with the GST and E-Way Bill systems. The e-invoice data is transmitted to the GST system, where it automatically populates the GSTR-1 return. The data is also sent to the e-way bill system, which generates Part A of the e-way bill. If transporter details are provided, Part B is also generated; otherwise, Part B can be generated later. This integration significantly streamlines the taxpayer's workflow by reducing multiple data entries.
How are electronic invoices created?
Electronic invoices can be created through several methods:
- Using an offline tool.
- Utilizing a GST Suvidha Provider.
- Direct integration with the IRP.
- Via API integration with a sister concern GSTIN.
- Using E-way Bill API credentials.
- Through GePP.
For bulk IRN generation using an offline tool, taxpayers should download the tool from the official portal (https://einvoice1.gst.gov.in/). After entering and validating invoice details, a JSON file is generated and uploaded to the portal post-login. For other methods, taxpayers must register their APIs on the e-invoice portal and use API credentials to connect and generate IRNs and e-way bills.
How can an e-invoice be generated for services?
An e-invoice for service supplies can be generated similarly to any other invoice. The process involves specifying the relevant SAC code, the total price as a unit rate, and a quantity of one.
What is the procedure for uploading invoices without using an ERP system?
E-invoice portals, such as NIC, allow sellers to report invoices for e-invoice generation even without an ERP system. These browser-based, user-friendly portals facilitate e-invoice generation and can also be accessed via mobile applications.
E-Invoice Structure and Schema
What is the appearance of an e-invoice format?
The e-invoice format is comprehensive and designed to accommodate various industries and businesses within a single structure. An example of an e-invoice format can be found in official guidelines.
What information does an e-invoice contain?
According to the GSTN's draft format, an e-invoice consists of the following components:
- e-Invoice Schema: This outlines the technical field names and descriptions, indicating whether a field is mandatory, providing sample values, and including explanatory notes.
- Masters: These define pre-defined sets of inputs for specific fields by the GSTN, such as UQC, State Code, invoice type, and supply type.
- e-Invoice Template: This template adheres to GST rules, helping users correlate terms across different sections. Mandatory fields are typically highlighted in green, while optional fields are in yellow.
What are the different types of fields in an e-invoice?
- Mandatory Fields: Data for these fields must be provided. If no value exists, it can be reported as 'nil'.
- Optional Fields: These fields may or may not be filled. They are relevant for specific businesses and scenarios.
- Optional Sections with Mandatory Fields: Some sections, though marked 'Optional', may contain mandatory fields. For instance, in the 'e-way bill details' section (which is optional), the 'Mode of Transportation' field is mandatory.
Will the e-invoice format be consistent across all taxpayer categories?
All businesses are required to issue e-invoices using the uniform e-invoice schema established by the GSTN. This schema includes both mandatory and non-mandatory fields. All taxpayers must complete the mandatory fields, while specific businesses can utilize non-mandatory fields as per their requirements.
What is the maximum number of line items supported by an e-invoice?
An e-invoice can support a maximum of 1000 line items.
Is the e-invoice required to be signed again by the supplier?
Rule 46 of the Central Goods and Services (CGST) Rules, 2017, generally requires the supplier's signature or digital signature on invoices. However, a proviso to Rule 46 states that a signature/digital signature is not required for electronic invoices compliant with the Information Technology Act, 2000. Therefore, it is interpreted that suppliers are not required to manually sign or digitally sign e-invoices, nor do they need to upload a digital signature to the e-invoice portal.
Can a business incorporate its logo into the e-invoice template?
No, the e-invoice schema does not provide a specific placeholder for a company's logo. Businesses can include their logo in their accounting or billing software, but it will not be transmitted to the IRP.
How should freight charges be reported in an e-invoice?
Freight charges can be reported as line items if they include a GST component. Otherwise, they should be entered under the 'Other charges' field.
Is it possible to report the Shipping bill number and date in an e-invoice, and is it mandatory?
Yes, the shipping bill number and date can be included in the e-invoice, but it is not mandatory. Refer to the invoice schema for detailed guidance.
E-Invoice Reporting Procedures
What is the deadline for generating an e-invoice after preparing a manual invoice and e-way bill?
Until October 31, 2023, there was no specified time limit for e-invoice generation. However, from November 1, 2023, taxpayers with an AATO of Rs. 100 crore or more must generate e-invoices within 30 days of raising the invoice or credit/debit note. Documents not compliant with this deadline will be considered invalid. For other taxpayers, no specific time limit is defined; it is advised to generate e-invoices on or after the invoice date but before filing GSTR-1 returns.
Is an invoice or credit/debit note valid without an IRN if a notified person is required to report it to the IRP?
Under Rule 48(4) of the CGST Rules, a notified person must prepare an invoice by uploading specified particulars in Form GST INV-01 to the IRP and obtaining an IRN. Rule 48(5) further states that any invoice issued by such persons in a manner other than that specified in Rule 48(4) will not be considered a valid invoice. Consequently, an invoice or debit/credit note issued by a notified person is legally valid only if it includes an IRN.
Is there a time limit for reporting invoices to the IRP for IRN generation?
Until October 31, 2023, there was no time limit for IRN generation. However, effective November 1, 2023, taxpayers with an AATO of Rs. 100 crore and above must generate e-invoices within 30 days of the invoice or credit/debit note date. Failure to meet this deadline will render the invoices/CDNs non-compliant.
What types of documents must be reported to the IRP?
The following documents are subject to e-invoicing:
- Invoices issued by the supplier.
- Credit Notes issued by the supplier.
- Debit Notes issued by the supplier.
- Any other document required by law to be reported by its creator.
What are the available methods for registering e-invoices on the IRP?
Multiple methods are available for registering e-invoices on the Invoice Registration Portal (IRP). These include:
- Web-based interfaces.
- API-based integration.
- Offline tools.
- GSP-based solutions.
What are the prerequisites for generating an e-invoice?
To generate e-invoices, the following conditions must be met:
- The individual generating the e-invoice must be registered on the GST portal and the e-invoice or e-way bill portal.
- A valid document, such as an invoice, debit note, or credit note, must be available.
- For bulk e-invoice generation, the taxpayer should have a valid JSON file conforming to the e-invoice schema or have integrated their ERP system with APIs.
How can the authenticity of an e-invoice be verified?
An e-invoice's authenticity can be verified by uploading the signed JSON file to the e-invoice system via the 'Verify Signed Invoice' option under the 'Search' menu. Alternatively, users can download the QR Code Verify app to scan and verify the QR code printed on the invoice.
Can multiple IRNs be generated for the same invoice?
No, the e-invoice system checks the Central Registry of the GST system to prevent multiple IRNs from being generated for the same invoice from the same supplier within the same financial year. The IRP will reject such duplicate invoices.
Can a cancelled e-invoice number be reused?
No, once an IRN is cancelled, the same invoice number cannot be used again to generate another invoice. Any attempt to do so will be rejected by the IRP.
Can e-commerce operators generate e-invoices on behalf of sellers using their platforms?
Yes, if suppliers selling through an e-commerce entity are notified persons required to report invoices under Rule 48(4), the e-commerce operator can generate e-invoices on their behalf.
Amending and Cancelling E-Invoices
Can an e-invoice be partially or fully cancelled?
An e-invoice cannot be partially cancelled; it must be cancelled in its entirety. Once cancelled, the cancellation must be reported on the IRN within 24 hours. Cancellations performed after 24 hours cannot be done on the IRN and require manual cancellation on the GST portal within the GSTR-1 return before its filing.
How can an e-invoice be amended?
All amendments to an e-invoice can only be made on the GST portal within the GSTR-1 return.
E-Invoicing Integration with GST Returns and E-Way Bill System
Is there a time limit for goods delivery or e-waybill generation in conjunction with an e-invoice?
No, there is currently no defined time limit for the delivery of goods or the generation of an e-way bill related to an e-invoice.
How will the e-invoicing system be integrated with GST returns?
An e-invoice is uploaded into the relevant GST return only after it has been validated and registered by the invoice registration system. Once validated, it becomes visible to the taxpayer for review and editing in the GSTR-1 return. From the supplier's GSTR-1, the data is automatically populated into the recipient's (buyer's) GSTR-2A/2B/4A or 6A, as applicable.
The tax department's primary goal is to enable the pre-population of GST returns, thereby minimizing reconciliation issues. With e-invoicing implemented, invoice data can be pre-filled into the relevant tables of tax returns, eliminating the need for fresh data entry.
Will a facility for invoice generation be available on the common GST portal?
No, invoices will continue to be generated using individual ERP software employed by businesses. The invoice must comply with the e-invoicing standard and include all mandatory parameters. Direct invoice generation on a common portal will not be available.
After IRN generation, is there a time limit for e-way bill generation (where applicable)?
No, currently there is no time limit within the system for generating an e-way bill after the IRN has been generated.
Do taxpayers need to verify e-invoice details automatically populated in the GSTR-1 return before filing?
The GSTN has issued advisories clarifying that the auto-population of e-invoice details into GSTR-1 is merely a convenience for taxpayers. The statutory obligation to file an accurate GSTR-1, based on documents raised during the relevant tax period, rests with the taxpayer.
Due to GSTR-1 validations, some reported e-invoices might not auto-populate into the relevant tables, although they may appear in the downloadable Excel file on the GSTR-1 dashboard with error descriptions. Taxpayers can correct and re-upload this data before filing their GSTR-1. Therefore, taxpayers must verify the data in each field and file the return in accordance with the relevant legal provisions. In addition to auto-populated e-invoices, taxpayers must manually add details of any other supplies made during the tax period into the respective tables of the GSTR-1.
How can auto-populated e-invoice data in GSTR-1 tables be deleted and new data added?
On the GST portal (online method): Use the 'Reset' button at the bottom of the GSTR-1 dashboard. This action deletes all details from the GSTR-1 tables, including auto-populated e-invoice records. To delete specific records, navigate to the relevant GSTR-1 table, select the record(s), and click 'Delete' in the action column (within the 'Processed Invoices/Documents' table).
Using the offline utility: Records can be deleted by following these steps:
- Download the GSTR-1 JSON for the applicable tax period.
- Open the JSON file in the GSTR-1 offline tool.
- Select the relevant table from the 'Select Section' drop-down menu.
- Click the 'Delete Section Data' button and confirm with 'Yes'.
- Alternatively, select specific records or check the 'Select All' checkbox and click the 'Delete' button located below the table.
- A confirmation will appear, indicating that the records in the selected table are marked for deletion.
- Once 'Delete' is clicked, the record is flagged for deletion.
- View the summary and generate the JSON file.
- Upload the generated JSON file to the GST portal.
- After processing the uploaded JSON file, all or selected records will be deleted from their respective tables.
Invoice Registration Portal (IRP) for E-Invoicing
Is there a time limit for uploading e-invoices to the IRP?
Until October 31, 2023, there was no time limit for e-invoice generation. However, from November 1, 2023, taxpayers with an AATO of Rs. 100 crore or more must generate e-invoices within 30 days of the invoice or credit/debit note date. Failure to meet this deadline will result in non-compliant documents. For other taxpayers, where no specific time limit is defined, it is advised to create e-invoices on or after the invoice date but before filing GSTR-1 returns.
Is it possible to upload invoices in bulk?
Yes, invoice details can be entered in bulk using an Excel-based bulk converter tool available on the e-invoice portal. After generating the JSON file, it must be uploaded to the e-invoice portal post-login. The IRN and QR code will be generated and returned in a response JSON file.
How long will data be retained on the Government Portal?
On the IRP, data remains available for only 24 hours. However, once an invoice is registered and validated, it is uploaded into the relevant GST return, where it remains accessible for the entire financial year.
What actions should be taken if an e-invoice system account is frozen?
If an e-invoice portal account is frozen, it typically indicates that the GSTIN has been deactivated or the registration cancelled on the GST common portal. Taxpayers should check their GSTIN status under the 'Search Taxpayer' tab on the GST common portal. If login to the GST portal is possible but not the e-invoice portal, a complaint can be filed at https://selfservice.gstsystem.in/.
Other Common E-Invoicing Queries
Are electronic invoices considered legal?
Yes, electronic invoices are legally valid because each one is verified and authenticated by the IRP on behalf of the GSTN.
Which countries have adopted e-invoicing systems?
Several countries have already implemented e-invoicing, including the Kingdom of Saudi Arabia, Malaysia, South Korea, Brazil, Chile, Mexico, Canada, Norway, Sweden, Turkey, Italy, Denmark, and Peru.
What e-invoicing software standard is utilized?
The GSTN, in collaboration with the ICAI (Institute of Chartered Accountants of India), developed the e-invoice standard. This standard is based on PEPPOL (Pan European Public Procurement Online), which uses the UBL (Universal Business Language) standard. It integrates requirements from tax laws and features necessary for international trade.
Mandatory features under GST law are marked as mandatory fields in the e-invoice. Other features are optional, allowing businesses to decide whether to enter them.
Do export transactions require e-invoice compliance?
Yes, e-invoice compliance is mandatory for export transactions. The e-invoice system supports the declaration of export invoices as well as zero-rated supplies.
Are import transactions subject to e-invoice compliance?
No, e-invoicing is not applicable to import transactions or bills of entry.
Are SEZ developers required to issue e-invoices?
Yes, SEZ developers must issue e-invoices if their turnover exceeds the specified limit and they meet other conditions outlined in relevant notifications. Only SEZ units are exempt from issuing e-invoices.
Where should the QR code, Invoice Reference Number (IRN), and acknowledgement number be placed on the e-invoice?
There is no specific location mandated for printing these details on the invoice. However, it is essential to ensure that these details are clearly visible and that the QR code can be scanned for verification.
Is e-invoicing applicable if customers operate from an SEZ?
Yes, e-invoicing applies to buyers operating from an SEZ. If the customer is an SEZ type, the seller can generate an e-invoice using the transaction type 'SEZWP' (SEZ with payment) or 'SEZWOP' (SEZ without payment).
We are encountering an issue where a slash '/' cannot be entered in the document number. What should be done?
Document numbers in e-invoices should not begin with '0', '/', or '-'. These characters should be omitted from the document number.
Can manual invoices with foreign currencies (e.g., USD or EURO) and corresponding e-invoices in INR be used? Can export invoice details be reported with foreign currency?
All invoices reported on the e-invoice portal must have values stated in INR. However, some optional fields within the e-invoice schema may allow the use of foreign currency.
Is e-invoicing applicable to invoices issued by an Input Service Distributor (ISD)?
No, e-invoicing is not applicable to invoices issued by an ISD.
If an SEZ unit and a regular DTA unit are part of the same legal entity (sharing the same PAN), and their combined aggregate turnover exceeds the notified limit in any financial year since 2017-18, will e-invoicing apply to the DTA unit even if its individual turnover is below the limit?
In this scenario, while the SEZ unit is exempt from e-invoicing, e-invoicing will still apply to the DTA unit. This is because the aggregate turnover of the legal entity (based on the common PAN) exceeds the notified limit. Turnover is calculated as per Section 2(6) of the CGST Act, which considers the 'aggregate turnover' across the common PAN.
How can one determine if a particular supplier is required to issue e-invoices?
The responsibility to issue an e-invoice under Rule 48(4) rests with the taxpayer upon meeting the prescribed conditions. As a facilitation measure, all taxpayers who have exceeded the specified turnover in any financial year from FY 2017-18 onwards are enabled to report invoices to the IRP.
To check a GSTIN's enablement status, visit the e-invoice portal and navigate to 'Search' -> 'e-invoice status of the taxpayer'. This listing is based solely on GSTR-3B turnover reported to the GSTN and may include exempt entities or those not subject to e-invoicing for other reasons. Therefore, enablement status does not automatically imply a mandate to generate e-invoices. A taxpayer's turnover slab can also be verified on the GST portal under the 'Search Taxpayer' / 'Know Your Supplier' tabs.
Is there a comprehensive list of all taxpayers obligated to generate e-invoices?
There is no precise, static list of taxpayers required to generate e-invoices, as the conditions for e-invoicing (e.g., turnover thresholds, exemptions, nature of supplies) are dynamic. However, taxpayers can access a list of GSTINs that are eligible for or currently generating IRNs on the IRP. This list is updated periodically.
This list is available on the e-invoice portal by navigating to 'Others' -> 'GSTINs Generating IRN'. This list may include names of exempt entities shown as enabled for e-invoice. The onus remains on the taxpayer to verify conditions and comply with the law. Recipients of supplies can also verify this information with their suppliers.
Can e-invoices be printed?
Yes, both suppliers and buyers can print e-invoices by utilizing the QR code on the signed e-invoice returned by the IRP.
Is e-invoicing applicable to B2C transactions?
Currently, e-invoice provisions do not apply to B2C transactions. However, sellers are required to display a dynamic QR code on B2C invoices as per Notification No. 14/2020 – Central Tax dated March 21, 2020, and Notification No. 6/2021 – Central Tax dated March 30, 2021.
What data is embedded in the QR code?
The QR code contains the following data:
- GSTIN of the supplier and recipient.
- Invoice Number.
- Date of invoice generation.
- Invoice value.
- Number of line items.
- HSN code of the item with the highest taxable value.
- Unique IRN.
- Date of IRN generation.
What are the penalties for failing to generate an e-invoice?
Failure to generate an e-invoice incurs a penalty of 100% of the tax due or Rs. 10,000, whichever amount is higher. Additionally, the penalty for issuing an incorrect invoice is Rs. 25,000 per invoice.