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What is e-Invoicing Under GST? Applicability, Limit & Implementation Date

By Annapoorna

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Updated on: Feb 7th, 2024

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22 min read

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e-Invoicing under GST denotes electronic invoicing defined by the GST law. Just like how a GST-registered business uses an e-way bill while transporting goods from one place to another. Similarly, certain notified GST-registered businesses must generate e invoice for Business-to-Business (B2B) transactions.

Clear is officially GSTN-approved IRP. More than 3,000 large enterprises trust the Clear e-Invoicing solution for unified e-invoicing and e-way bill compliance journey. We provide the best-in-class e-invoicing solution for businesses of any scale and industry. Do not miss exploring the Clear e-Invoicing solution!

Latest Updates

12th June 2023  
The NIC has made it mandatory for taxpayers with turnover more than Rs.100 Crore to login using the Two-factor Authentication from 15th July 2023 for both the e-invoicing and e-way bill systems.  

9th June 2023  
The GSTN has launched an ‘e-Invoice QR Code Verifier’ app on Google Play Store to enable users to quickly and conveniently verify e-invoices. The user-friendly app will authenticate the information embedded in the QR code, which can be compared with the information printed on the e-invoice. The iOS version will be available shortly.  

10th May 2023  
CBIC notified the 6th phase of e-invoicing. Hence, taxpayers with ₹5 Cr+ turnover in any financial year from 2017-18 shall issue e-invoices w.e.f 1st August 2023.  

6th May 2023  
The GST department has deferred the time limit of 7 days to report the old e-invoices on the e-invoice IRP portals by three months. Further, the department is yet to announce the new implementation date.  

13th April 2023  
As per the GST Network's advisories dated 12th April 2023 and 13th April 2023, taxpayers with annual turnover equal to or more than Rs.100 crore must report tax invoices and credit-debit notes to IRP within 7 days of invoice date from 1st May 2023.  

30th January 2023  
Few updates are made on the NIC's e-invoice portal-  
(1) User can select POS state code of '96-Other Country' against items where HSN codes are 9965 and 9968 (Services by way of transportation of goods, including by mail or courier).  
(2) The documents dated 1/10/2021 or after shall only be considered on the portal.  
(3)  The portal has added a new error code 2295 for duplicate requests apart from 2150, with error as 'IRN is already  
generated and registered with GSTN Lookup Portal by other IRP'.  
   
11th October 2022  
The GST Council may implement the next phase of e-invoicing for businesses with an annual turnover of more than Rs.5 crore from 1st January 2023. The system may get extended to businesses with a turnover of over Rs.1 crore by the end of the next fiscal year.  
 

What is e-invoicing under GST?

‘e-Invoicing’ or ‘electronic invoicing’ is a system in which B2B invoices and a few other documents are authenticated electronically by GSTN for further use on the common GST portal.

In its 35th meeting, the GST Council decided to implement a system of e-Invoicing, covering specific categories of persons, mostly large enterprises. Later on, it has been expanded to cover mid-sized businesses and small businesses as well.

e-Invoicing does not imply the generation of invoices on the GST portal but it means submitting an already generated standard invoice on a common e invoice portal. Thus, it automates multi-purpose reporting with a one-time input of invoice details. The CBIC notified a set of common portals to prepare e invoice via Notification No.69/2019 – Central Tax.

Under the electronic invoicing system, an identification number will be issued against every invoice by the Invoice Registration Portal (IRP), managed by the GST Network (GSTN). The National Informatics Centre launched the first IRP at einvoice1.gst.gov.in.

All invoice information gets transferred from this portal to both the GST portal and the e-way bill portal in real-time. Therefore, it eliminates the need for manual data entry while filing GSTR-1 returns and generation of part-A of the e-way bills, as the information is passed directly by the IRP to the GST portal.

Who must generate e invoice and its Applicability?

The e invoice applicability can be explained as follows-

Turnover criteria or e Invoice limit

PhaseApplicable to taxpayers having an aggregate turnover of more thanApplicable dateNotification number
IRs 500 crore01.10.202061/2020 – Central Tax and 70/2020 – Central Tax
IIRs 100 crore01.01.202188/2020 – Central Tax
IIIRs 50 crore01.04.2021
5/2021 – Central Tax
IVRs 20 crore01.04.20221/2022 – Central Tax
VRs 10 crore01.10.202217/2022 – Central Tax
VIRs 5 crore01.08.202310/2023 - Central Tax

The taxpayers must comply with e-invoicing in FY 2022-23 and onwards if their e invoice limit or turnover exceeds the specified limit in any financial year from 2017-18 to 2021-22. Also, the aggregate turnover will include the turnover of all GSTINs under a single PAN across India.

If the turnover in the last FY was below the threshold limit but it increased beyond the threshold limit in the current year, then e-Invoicing would apply from the beginning of the next financial year i.e. FY 2023-24.

Suppose, ABC ltd aggregate turnover was as follows-  
FY 2017-18: Rs 15 crore  
FY 2018-19: Rs 17 crore  
FY 2019-20: Rs 24 crore  
FY 2020-21: Rs 19 crore  
FY 2021-22: Rs 18 crore

Suppose, QPR ltd started business in FY 2019-20 and earned aggregate turnover as follows-  
FY 2019-20: Rs 4 crore  
FY 2020-21: Rs 7 crore  
FY 2021-22: Rs 11 crore   

The ABC Ltd shall mandatorily generate e invoices from 01.04.2022 irrespective of the current year’s aggregate turnover as it has crossed the Rs 20 crore turnover limit in FY 2019-20.

On the other hand, QPR ltd should comply with e-Invoicing from 1st October 2022 since its previous year’s annual turnover exceeds Rs.10 crore.

The fifth phase of e-Invoicing works similar to the fourth phase. Watch the below video to learn easily.

Transactions and documents criteria

The following transactions and documents listed below fall under   
e invoicing applicability –

DocumentsTransactions
Tax invoices, credit notes and debit notes under Section 34 of the CGST ActTaxable Business-to-Business sale of goods or services, Business-to-government sale of goods or services, exports, deemed exports, supplies to SEZ (with or without tax payment), stock transfers or supply of services to distinct persons, SEZ developers, and supplies under reverse charge covered by Section 9(3) of the CGST Act.

Who need not comply with e-Invoicing?

However, irrespective of the turnover, e-Invoicing shall not be applicable to the following categories of registered persons for now, as notified in CBIC Notification No.13/2020 – Central Tax, amended from time to time-

Notified BusinessesDocumentsTransactions
1)An insurer or a banking company or a financial institution, including an NBFC  
2) A Goods Transport Agency (GTA)  
3) A registered person supplying passenger transportation services  
4) A registered person supplying services by way of admission to the exhibition of cinematographic films in multiplex services  
5) An SEZ unit (excluded via CBIC Notification No. 61/2020 – Central Tax)  
6) A government department and Local authority (excluded via CBIC Notification No. 23/2021 – Central Tax)   
7) Persons registered in terms of Rule 14 of CGST Rules (OIDAR)
Delivery challans, Bill of supply, financial or commercial credit note or debit note, bill of entry, and ISD invoices.Any Business-to-Consumers (B2C) sales, Nil-rated or non-taxable or exempt B2B sale of goods or services, nil-rated or non-taxable or exempt B2G sale of goods or services, imports, high sea sales and bonded warehouse sales, Free Trade & Warehousing Zones (FTWZ), and supplies under reverse charge covered by Section 9(4) of the CGST Act.

Systems before & after e-invoicing

Before e-invoicing could apply, businesses generated invoices through various software, and the details of these invoices were manually uploaded in the GSTR-1 return or using ERP.

Once the respective suppliers file the GSTR-1, the invoice information gets reflected in GSTR-2B for the recipients. On the other hand, the consignor or transporters had to generate e-way bills by again importing the invoices in Excel or JSON manually or via ERP.

Under the e-invoicing system, the process of generating and uploading invoice details will remain the same. It’s done by importing using the Excel tool/JSON or via API integration, either directly or through a GST Suvidha Provider (GSP). The data will seamlessly flow for GSTR-1 preparation and for the e-way bill generation too. The e-invoicing system will be the key tool to enable this.

Time limit to generate e-Invoice

Until 30th April 2023, there has been no time limit fixed by the GST systems or the GST law to generate e-invoices. From 1st May 2023* onwards, taxpayers with Annual Aggregate Turnover (AATO) equal to or more than INR 100 crore must generate e-invoices for tax invoices and credit-debit notes within 7 days of invoice date, failing which such invoices and CDNs will be considered non-compliant.

Further, there is no defined time limit or period within which e invoice must be generated for the rest of the applicable taxpayers. Therefore, such taxpayers are advised to create e invoice on or after the invoice/CDN date preferably a week before the filing of GSTR-1 returns since it takes T+3 days for details of e-invoices to get auto-populated into GSTR-1.

*However, on 6th May 2023, the department has deferred the time limit of 7 days to report the old e-invoices on the IRP portals by three months. Also, the department is yet to announce the new implementation date.

Process of getting an e invoice

The following are the stages involved in generating or raising an e-invoice.

  1. The taxpayer has to ensure to use of the reconfigured ERP system as per PEPPOL standards. He could coordinate with the software service provider to incorporate the standard set for e-invoicing, i.e. e invoice schema (standards) and must have the mandatory parameters notified by the CBIC, at least.
  2. Any taxpayer has got primarily two options for IRN generation:
    • The IP address of the computer system can be whitelisted on the e-invoice portal for a direct API integration or integration via GST Suvidha Provider (GSP) such as ClearTax.
    • Download the bulk generation tool to bulk upload invoices. It will generate a JSON file that can be uploaded to the e invoice portal to generate IRNs in bulk.
  3. The taxpayer must thereafter raise a regular invoice on that software. He must give all the necessary details like billing name and address, GSTN of the supplier, transaction value, item rate, GST rate applicable, tax amount, etc.
  4. Once either of the above options is chosen, raise the invoice on the respective ERP software or billing software. Thereafter, upload the details of the invoice, especially mandatory fields, onto the IRP using the JSON file or via an application service provider (app or through GSP) or through direct API. The IRP will act as the central registrar for e-invoicing and its authentication. There are several other modes of interacting with IRP, such as SMS-based and mobile app-based.
  5. IRP will validate the key details of the B2B invoice, check for any duplications and generate an invoice reference number (hash) for reference. There are four parameters based on which IRN is generated: Seller GSTIN, invoice number, FY in YYYY-YY, and document type (INV/DN/CN).
  6. IRP generates the invoice reference number (IRN), digitally signs the invoice and creates a QR code in Output JSON for the supplier. On the other hand, the seller of the supply will get intimated about the e invoice generation through email (if provided in the invoice).
  7. IRP will send the authenticated payload to the GST portal for GST returns. Additionally, details will be forwarded to the e-way bill portal, if applicable. The GSTR-1 of the seller gets auto-filled for the relevant tax period. In turn, it determines the tax liability.

A taxpayer can continue to print his invoice as being done presently with a logo. The e-invoicing system only mandates all taxpayers to report invoices on IRP in electronic format.

Benefits of e-Invoicing to businesses

Businesses will have the following benefits by using e-invoice initiated by GSTN-

  • e-Invoice resolves and plugs a major gap in data reconciliation under GST to reduce mismatch errors.
  • e-Invoices created on one software can be read by another, allowing interoperability and helping reduce data entry errors.
  • Real-time tracking of invoices prepared by the supplier is enabled by e invoice.
  • Backward integration and automation of the GST return filing process – the relevant details of the invoices would be auto-populated in the various returns, especially for generating part-A of e-way bills.
  • Faster availability of genuine input tax credit.
  • Lesser possibility of audits/surveys by the tax authorities since the information they require is available at a transaction level.
  • Faster and easy access to formal credit routes such as invoice discounting or financing, especially for small businesses.
  • Improved customer relations and growth in prospects for small businesses to do business with large enterprises.

How can e-invoicing curb tax evasion?

It will help in curbing tax evasion in the following ways-

  • Tax authorities will have access to transactions as they take place in real-time since the e invoice will have to be compulsorily generated through the GST portal.
  • There will be less scope for manipulating invoices since the invoice gets generated before carrying out a transaction.
  • It will reduce the chances of fake GST invoices, and only genuine input tax credit can be claimed as all invoices need to be generated through the GST portal. Since the input credit can be matched with output tax details, it becomes easier for GSTN to track fake tax credit claims.

What are the mandatory fields of an e-invoice?

e-Invoice must primarily adhere to the GST invoicing rules. Apart from this, it should also accommodate the invoicing system or policies followed by each industry or sector in India. Certain information is made mandatory, whereas the rest of it is optional for businesses. Many fields are also made optional, and users can choose to fill up relevant fields only. It has also described every field along with the sample inputs for the interested users. One can see that certain required fields from the e-way bill format are included now in the e-invoice, such as the sub-supply type.

Below is the gist of the contents of the latest e-invoice format as notified on 30th July 2020 via Notification No.60/2020 – Central Tax:

  1. 12 sections (mandatory + optional) and six annexures consisting of a total of 138 fields.
  2. Out of the 12 sections, five are mandatory, and seven are optional. Two annexures are mandatory.
  3. The five mandatory sections are basic details, supplier information, recipient information, invoice item details, and document total. The two mandatory annexures are details of the items and the document total.

The following fields must be compulsorily be declared in an e-invoice:  

Sl. no.Name of the fieldList of choices/ specifications/sample InputsRemarks
1Document Type CodeEnumerated List such as INV/CRN/DBNType of document must be specified
2Supplier_Legal NameString Max length: 100 Legal name of the supplier must be as per the PAN card
3Supplier_GSTINMax length: 15  Must be alphanumeric GSTIN of the supplier raising the e-invoice
4Supplier_AddressMax length: 100 Building/Flat no., Road/Street, Locality, etc. of the supplier raising the e-invoice
5Supplier_PlaceMax length: 50 Supplier’s location such as city/town/village must be mentioned
6Supplier_State_CodeEnumerated list of statesThe state must be selected from the latest list given by GSTN
7Supplier PincodeSix digit codeThe place (locality/district/state) of the supplier’s locality
8Document NumberMax length: 16 Sample can be “ Sa/1/2019”For unique identification of the invoice, a sequential number is required within the business context, time frame, operating systems and records of the supplier. No identification scheme is to be used.
9Preceeding_Invoice_Reference and dateMax length:16 Sample input is  “ Sa/1/2019” and “16/11/2020”Detail of original invoice which is being amended by a subsequent document such as a debit and credit note. It is required to keep future expansion of e-versions of credit notes, debit notes and other documents required under GST.
10Document DateString (DD/MM/YYYY) as per the technical field specificationThe date when the invoice was issued. However, the format under explanatory notes refers to ‘YYYY-MM-DD’. Further clarity will be required. Document period start and end date must also be specified if selected.
11Recipient_ Legal NameMax length: 100The name of the buyer as per the PAN
12Recipient’s GSTINMax length: 15The GSTIN of the buyer to be declared here
13Recipient’s AddressMax length: 100Building/flat no., road/street, locality, etc. of the supplier raising the e-invoice
14Recipient’s State CodeEnumerated listThe place of supply state code to be selected here
15Place_Of_Supply_State_ CodeEnumerated list of statesThe state must be selected from the latest list given by GSTN
16PincodeSix digit codeThe place (locality/district/state) of the buyer on whom the invoice is raised/ billed to must be declared here if any
17Recipient PlaceMax length: 100Recipient’s location (City/Town/Village)
18IRN- Invoice Reference NumberMax length: 64 Sample is ‘a5c12dca8 0e7433217…ba4013 750f2046f229’At the time of the registration request, this field is left empty by the supplier. Later on, a unique number will be generated by GSTN after uploading the e-invoice on the GSTN portal. An acknowledgement will be sent back to the supplier after the successful acceptance of the e-invoice by the portal. IRN should then be displayed on the e-invoice before use.
19ShippingTo_GSTINMax length: 15GSTIN of the buyer himself or the person to whom the particular item is being delivered to
20Shipping To_State, Pincode and State codeMax length: 100 for state, 6 digit pincode and enumerated list for codeState pertaining to the place to which the goods and services invoiced were or are delivered
21Dispatch From_ Name, Address, Place and PincodeMax length: 100 each and 6 digit for pincodeEntity’s details (name, and city/town/village) from where goods are dispatched
22Is_ServiceString (Length: 1) by selecting Y/NWhether or not supply of service must be mentioned
23Supply Type CodeEnumerated list of codes Sample values can be either of B2B/B2C/ SEZWP/S EZWOP/E XP WP/EXP WOP/DE XPCode will be used to identify types of supply such as business to business, business to consumer, supply to SEZ/exports with or without payment, and deemed export.
24Item DescriptionMax length: 300 The sample value is ‘Mobile’ The schema document refers to this as the ‘identification scheme identifier of the Item classification identifier’Simply put, the relevant description is generally used for the item in the trade. However, more clarity is needed on how it needs to be described for every two or more items belonging to the same HSN code. 
25HSN CodeMax length: 8The applicable HSN code for particular goods/service must be entered
26Item_PriceDecimal (12,3) Sample value is ‘50’The unit price, exclusive of GST, before subtracting item price discount, can not be negative
27Assessable ValueDecimal (13,2) Sample value is ‘5000’The price of an item, exclusive of GST, after subtracting the item price discount. Hence, gross price (-) discount = net price item, if any cash discount is provided at the time of sale
28GST RateDecimal (3,2) Sample value is ‘5’The GST rate represented as a percentage that is applicable to the item being invoiced
29IGST Value, CGST Value and SGST Value SeparatelyDecimal (11,2) Sample value is ‘650.00’For each individual item, IGST, CGST and SGST amounts have to be specified
30Total Invoice ValueDecimal (11,2)The total amount of the Invoice with GST. Must be rounded to a maximum of 2 decimals

Format of sample e-invoice

The e-invoice format notified is as follows:  

 e-invoice format

Check out the detailed format of an e-invoice

How does Clear e-Invoicing help?

Team Clear provides the best-in-class e-invoicing solution for businesses. The Clear e-invoicing solution also provides an e-Invoicing Tally Connector, enabling taxpayers to perform e-invoicing activities without leaving a tally screen. Team Clear ensures a safe migration to an upgraded UI with no changes to your historical data.

Team Clear also offers various modes through which e-invoices can be generated by the taxpayers, such as seamless API integrations, Excel mode, FTP, SFTP or Tally connector. The user can enjoy numerous value additions such as-

  • Seamless generation of 5,000 e-invoices per minute
  • Integration with a high-fidelity solution with 99.99% uptime
  • 100+ data validations to ensure an error-free smooth e-invoicing experience
  • Auto-retry of failed EWBs (with distance error) to improve the success rate of EWB generation
  • Automatic generation of the e-way bill after IRN generation without any ingestion of data
  • Faster loading of ‘e-invoices’ and ‘e-way bills’ on the screen for as many as 1 lakh documents
  • Reconciliation vis-a-vis e-way bill and GSTR-1 data, insightful reports, customised print template for e-invoice, data archiving, etc.

FAQs on e-invoicing

To whom will e-invoicing apply?

E-invoicing applies to GST registered persons whose aggregate turnover in any previous financial years (2017-18 to 2021-22) exceeded Rs.20 crore. From 1st August 2023, it applies to those with a turnover of more than Rs.5 crore up to Rs.10 crore. There are exceptions as listed in the above section.

Can an e-invoice be cancelled partially/fully?

An e-invoice cannot be cancelled partially but can be cancelled wholly. On cancellation, it must be reported to the IRN within 24 hours. Any attempt to cancel thereafter cannot be done on the IRN and must be manually cancelled on the GST portal before the returns are filed.

Will the bulk uploading of invoices for the generation of IRN be possible?

No, invoices must be uploaded one at a time into the IRP. The ERP of a business will need to be designed to place the request for the upload of individual invoices.

Will there be a facility for e-invoice generation on the common GST portal?

No, invoices will continue to be generated on the individual ERP software currently in use by businesses. The invoice must adhere to the e-invoicing standard format and include the mandatory parameters. The direct generation of invoices on a common portal is not being planned at the moment.

What are the types of documents that are to be reported to the IRP?
Invoices by the supplier, credit notes, debit notes as per the GST law, or any other document as notified under GST law are to be reported as an e-invoice.

For more FAQs on e-Invoicing, read our article on e-Invoicing FAQs.

About the Author

I preach the words, “Learning never exhausts the mind.” An aspiring CA and a passionate content writer having 4+ years of hands-on experience in deciphering jargon in Indian GST, Income Tax, off late also into the much larger Indian finance ecosystem, I love curating content in various forms to the interest of tax professionals, and enterprises, both big and small. While not writing, you can catch me singing Shāstriya Sangeetha and tuning my violin ;). Read more

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