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E-invoice applicability under GST

CA Sitaram PareekLast reviewed June 20266 min read

GST e-invoicing requires notified businesses to report B2B and export invoices to the Invoice Registration Portal (IRP), which validates them and returns an Invoice Reference Number (IRN) and a QR code. It currently applies to taxpayers with aggregate annual turnover exceeding Rs.5 crore in any financial year since 2017-18.

The threshold and scope

E-invoicing was rolled out in phases by turnover and now applies to taxpayers whose aggregate turnover exceeded Rs.5 crore in any financial year from 2017-18 onwards (effective 1 August 2023). It covers B2B supplies, supplies to SEZ, exports, and credit/debit notes. It does not apply to B2C invoices (though dynamic QR for B2C is a separate requirement).

Rule 48(4), CGST Rules. Notified classes of registered persons must prepare invoices by reporting prescribed particulars to the IRP and obtaining an IRN.

How the IRN mechanism works

  1. The supplier creates the invoice in its accounting/ERP system.
  2. The invoice JSON is uploaded to the IRP.
  3. The IRP validates it, generates a unique IRN and a signed QR code, and returns them.
  4. Data auto-flows to GSTR-1 and the e-way bill system.

An invoice issued without a valid IRN, where e-invoicing applies, is not a valid tax invoice, and the recipient may be denied ITC.

Who is exempt

Specified categories are exempt regardless of turnover: SEZ units (not developers), insurers, banking companies and financial institutions, goods transport agencies, passenger transport services, and suppliers of admission to cinematograph/multiplex exhibitions. Verify the current exempt list before concluding.

The 30-day reporting window

Taxpayers above a notified turnover must report invoices to the IRP within 30 days of the invoice date; older invoices are rejected by the portal. Build IRN generation into the billing workflow so no B2B invoice is issued without it, and reconcile IRNs to GSTR-1 monthly.

Key takeaways

  • Applies above Rs.5 crore turnover for B2B, SEZ and export invoices.
  • IRP returns a unique IRN and signed QR code per invoice.
  • No valid IRN = not a valid tax invoice; recipient ITC at risk.
  • Report to the IRP within 30 days of the invoice date.

Frequently Asked Questions

What is the turnover limit for e-invoicing?

E-invoicing applies to taxpayers with aggregate turnover exceeding Rs.5 crore in any financial year from 2017-18 onwards, effective 1 August 2023.

Is an invoice valid without an IRN?

No. Where e-invoicing is applicable, an invoice without a valid IRN is not a valid tax invoice, and the recipient's ITC can be denied.

Is there a time limit to generate an IRN?

Yes. Notified taxpayers must report invoices to the IRP within 30 days of the invoice date, after which the portal will not accept them.

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Written & reviewed by

CA Sitaram Pareek

Chartered Accountant (ICAI) and holder of the Diploma in International Taxation (DIIT-ICAI). Works in-house with a multinational group operating across India, the UAE and Singapore, handling GST compliance, direct tax, transfer pricing, DTAA advisory and FEMA matters. Every article on NumberIQ is written against the bare Act, current CBDT/CBIC notifications and official portals (incometax.gov.in, gst.gov.in, cbic.gov.in).

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