E-invoicing has become a significant aspect of GST compliance in India. With the latest notification, there are new rules for E-invoicing applicability from August 2023. This article provides a comprehensive overview of the updated regulations, including the threshold limit, requirements, and exemptions.

As per the Notification No 10/2023 dated 10th May 2023 the threshold limit of E-invoicing turnover has been reduced to 5 crores from 01st August 2023.

Thus, registered persons whose Aggregate turnover in any preceding Financial Year from 2017-18 onwards is more than 5crores then E-invoicing is mandatory from 01st August 2023.

If in any preceding year from FY 2017-18 (From 1.17.17) onwards the Aggregate Turnover exceeds 5 crores then E-invoicing is mandatory

Below are set of Examples :-

Year Case 1

Aggregate T/O in crores

Case 2

Aggregate T/O in crores

Case 3

Aggregate T/O in crores

2017-18 3 1.75 2
2018-19 4.5 3.50 3.5
2019-20 5.5 4.25 4.75
2020-21 1.5 2.50 2.25
2021-22 2.5 4.25 3.50
2022-23 3.75 6.50 4.75
2023-24 4.5 4.75 5.75
E-invoice from Aug 23 Applicable Applicable Not Applicable
Reasons In the preceding year 2019-20 the Aggregate T/O exceeds 5crores.

Thus, E-invoicing is applicable from Aug 23

In the preceding year 2022-23 the Aggregate T/O exceeds 5crores.

Thus, E-invoicing is applicable from Aug 23

Currently for Aug 23 onwards E-invoicing is not applicable, since the limit of 5 crores has not exceeded in any of the preceding years. But E-invoicing would be applicable from April 2024 onwards

What is Aggregate Turnover as per GST?

As per section 2(6) of the CGST/SGST Act “Aggregate turnover” includes the aggregate value of:

(i) all taxable supplies,

(ii) all exempt supplies,

(iii) exports of goods and/or service, and,

(iv) all inter-state supplies of a person having the same PAN.

Hence registered person with same PAN having multiple GSTINs must include all the Taxable, Exempt, Export turnover incurred under various GSTINs under the same PAN. Aggregate turnover is calculated as per PAN and not according to individual GSTIN.

The above shall be computed on all India basis and excludes taxes charged under the CGST Act, SGST Act, UTGST Act, and the IGST Act.

Aggregate turnover shall include all supplies made by the Taxable person, whether on his own account or made on behalf of all his principals.

Aggregate turnover does not include: –

  • Value of Inward supplies on which tax is levied on reverse charge basis
  • The value of goods after completion of job work is not includible in the turnover of the job-worker. It will be treated as supply of goods by the principal and will accordingly be includible in the turnover of the Principal.

♦ Although exempt supply is to be included in Aggregate turnover calculation, but no e-invoicing is to be done for exempt supply. As for nil rated and wholly exempt supplies bill of supply is issued and not invoice

Supplies and Documents:-

Documents and supplies for which E-invoicing is applicable, if Registered Persons Aggregate turnover on the basis of PAN in any preceding Financial Year from 2017-18(1.7.17) onwards is more than 5crores

1. Documents: –

  • Invoices
  • Debit Notes
  • Credit Notes

2. Supplies: –

  • B2B Supplies: -Supplies made to registered persons having GSTIN

This includes supplies made to registered persons under the same Pan having different GSTIN

Thus, supplies made to unregistered persons i.e., B2C supplies are not covered for E-invoicing

  • SEZ Supplies: -Supplies made to SEZ units with or without GST Paid
  • Export Supplies: -Export Supplies made with or without IGST Payment
  • Deemed Exports
  • Supplies made to Government Departments: –

♦ As per the recommendations made in the 50th GST Council Meeting and Circular No 198/10/2023 issued on 17th July 2023 clarified that supplies made to Government Departments or establishments/ Government agencies/ local authorities/ PSUs, etc. under rule 48(4) of CGST Rules whose turnover exceeds the prescribed threshold for generation of e-invoicing is required to issue e-invoices even if their GST Registration is solely for the purpose of Tax at source deducted as per provisions of section 51 of the Central Goods and Services Tax Act, 2017 for such supplies made to Government.

  • Supplies under RCM

If a registered person whose outward supplies attract Reverse Charge mechanism u/s 9(3), e-invoicing is mandatory

E-invoicing not applicable to which registered type of persons?

As per Notification no 13/2020 dated 21st March, 2020 registered persons referred in sub-rules (2), (3), (4) and (4A) of rule 54 are exempted from E-invoicing requirements.

1. Banking and Insurance Sector-Rule 54(2)

Where the supplier of taxable service is an: –

  • Insurer or
  • A Banking company or
  • A Financial Institution, including Non-Banking Financial Company

2. Goods Transport Agency-Rule 54(3)

Where the supplier of taxable service is a goods transport agency supplying services in relation to transportation of goods by road in a goods carriage.

3. Passenger Transport Service Supplier-Rule 54(4)

Where the supplier of taxable service is supplying passenger transportation service

4. Admission of exhibition of cinematograph films in Multiplex-Rule 54(4A)

A registered person supplying services by way of admission to exhibition of cinematograph films in multiplex screens

5. SEZ Unit 

As per Notification No 61/2020 dated 30th July 2020 only SEZ Units are exempted from E-invoicing, not SEZ Developers

As per the SPECIAL ECONOMIC ZONES ACT, 2005, SEZ Developer means a person who, or a State Government which, has been granted by the Central Government a letter of approval under sub-section (10) of section 3 and includes an Authority and a Co-Developer (the Developer or Co-Developer shall have at least twenty-six percent of the equity in the entity) to create business, residential or recreational facilities in a Special Economic Zone in case such development is proposed to be carried out through a separate entity or a special purpose vehicle being a company formed and registered under the Companies Act, 1956 (1 of 1956).

SEZ units are the units set up for the manufacture of goods or rendering of services.

Conclusion: The new E-invoicing applicability update starting from 1st August 2023 brings important changes for registered persons with an aggregate turnover exceeding 5 crores in any preceding financial year. By understanding the revised threshold limit and regulations, businesses can ensure timely compliance with E-invoicing requirements.


Hope this article was helpful. Do write a comment incase of any doubts/suggestions.

If any query related to GST do contact via WhatsApp at 9833631616 (No calls)  or email at casanjonaa@gmail.com

Author Bio

Qualification: CA in Practice
Company: Sanjonaa And Associates
Location: Mumbai, Maharashtra, India
Member Since: 29 Jun 2022 | Total Posts: 9
I am Chartered Accountant with professional experience in Accounting, Auditing, Consulting and Compliance Services to diverse sectors of business for various regulatory laws. View Full Profile

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More Under Goods and Services Tax


    1. CA Sanjonaa Shetty says:

      Hi Vishesh Rana,
      As per GST Rules ,ITC will not be allowed as the invoice will be considered invalid.
      As per GST Rules 48(4) normal invoice generated will be invalid if e invoicing is applicable to the suppliers .
      As per ITC Rules Sec 16(2) valid invoice should be present for taking input credit.
      So the invoice you have is without IRN (that is generated during E-invoicing) .Hence you won’t be able to take credit.
      If your supplier is not issuing you E-invoice immediately causing you loss while claiming ITC, then safeguard yourself by taking a declaration that ” In case of any queries from any State or Central Goods and Services Tax Authorities, on applicability of e-invoicing provisions, the concerned Supplier/ Vendor will be solely responsible”
      Thanks for reaching out to me. Have a nice day!

  1. Vishesh Rana says:

    Dear Sir,

    Please Confirm E-Invoice Copy Not Received From Supplier but Normal Tax Invoice Received from Supplier Kindly Confirm me ITC taken Normal Invoice

  2. Pradip Shelar says:

    Hello Madam,
    Our turnover is crossed 5 Cr in FY 2023-24. Do you have any documentation regarding e-invoicing applicable for businesses whose turnover exceeded 5 Crores in the previous year or from FY 2017-2018?
    I checked Notification no 13/2020. and it states: “whose aggregate turnover in a financial year
    exceeds one hundred crore rupees, as a class of registered person who shall prepare invoice
    and other prescribed documents, in terms of sub-rule (4) of rule 48 of the said rules in respect
    of supply of goods or services or both to a registered person.

  3. Rajat says:

    Hello Sir,
    Sir My business turnover does not exceed 40 lacs last year and even not crossed 5 cr limit in any previous years. But today I got email from GST of applicability of e-invoicing provisions on us. Kindly suggest whether e-invoicing is applicable on us Or not. Please answer.

  4. Rajender Choudary says:

    If company exceeds 5 cr turn over and 98% of business is from exempt category 2 % bills are Tax Invoices is E Invoice Applicable or not

    1. CA Sanjonaa Shetty says:

      Hi Rajendra,
      E invoice is applicable if aggregate turnover exceeds Rs 5 crore. Aggregate turnover includes Exempt supplies.
      So in your case e invoicing is applicable
      But you have to generate e invoice for only taxable supplies and not exempt supplies.

  5. M Srijesh Kumar says:

    My client is government department and they have registered in GST as Tax Deductor for deducting GST TDS. Can we use their same GST number as “Tax Deductor” for generating e invoice?

  6. THIRUPPATHI P says:

    I am a GST Consultant, my client committed mistake in previous financial year 2022-23 in e-invoice. Actually they forget to raise a bill and collect the money from the customer. Now the party asking to file the bill in GST portal. Is it possible now sir

    1. CA Sanjonaa Shetty says:

      Hi Thiruppati,
      As the last date for amendments is Nov 2023.
      So can prepare now an e invoice for FY 2022-23 Ensure to update in the current month’s GSTR 1 and GSTR 3B.
      Currently there is no time limit given for generating E-invoice.
      As per the latest Notification on E-invoicing from 1st October onwards time limit of 7 days from the date of supply will be the tile limit for generating E-invoice for Registered persons whose turnover exceeds Rs 100 crore .For those below Rs 100 crore there is no time limit

    1. CA Sanjonaa Shetty says:

      Hi Anil,
      Self issued invoice-Does it mean that on certain purchase from unregistered buyers you are issuing invoice?
      If yes-Then this is inward supply invoice raised for which there is no e invoicing .As e-invoicing is on Outward supplies.
      If no-You are issuing self invoice for your sales which falls under RCM Category then:-
      a) Invoice issued to unregistered buyers-Then no e invoice
      b) Invoice issued to registered buyers-Then yes , only exemption for Goods Transport Agency

  7. Sachin Patel says:

    In the case of Work Contract, Labour Contractor ( Construction Work Related ). is the limit of Rs. 5cr or 10cr for generating E Invoice from 01/08/2023

    1. CA Sanjonaa Shetty says:

      Hello Sachin,
      As per the GST E-invoice notification the limit of 5 crore is applicable to all registered persons irrespective of the type of business you are in .If your transactions are entirely B2C /Nil rated /Non GST/Exempted supplies then you do not have to generate e invoice .But otherwise you have to generate E-invoice once your turnover exceeds 5 crore limit.
      Thank you.

    1. CA Sanjonaa Shetty says:

      Hello Prem Kumar,
      E-invoicing is applicable to export supplies .
      Check point Supplies and Documents for your clarification.
      Thank you.

  8. victor says:

    we are doing both business like GTA and other taxable supply (18% ) if GTA exempt to e-invoices what about other taxable supply , guide me whether i take e-invoices for taxable supply or not

    1. CA Sanjonaa Shetty says:

      Hi Victor,
      The exemption is available to Entity as a whole .
      For eg: Banking Cos deals in buying and selling of bullion in addition to their normal banking services. But since exemption is available as an Entity ,thus Banking Company is entirely exempt from E-invoicing.
      Similarly for you E-invoicing is not applicable .
      But you are required to mention on your invoices that E-invoicing is not applicable because of GTA Exemption.

  9. Somex says:

    Hi Team,
    e Invoice is applicable on me wef 01.08.23.
    I am doing some job work, and want to know if
    e-Invoice needs to be made for Job Work Processing charges bill ?

    1. CA Sanjonaa Shetty says:

      Hello Dushyant Sharma,
      Interest income under GST is considered as exempt supply.
      Exempt supply turnover is to be included in Aggregate Turnover as per the definition of Aggregate turnover.
      So to answer to your question,
      Yes interest income on unsecured loans given is to be included in Aggregate turnover.

  10. Gursimran jit singh says:

    Hi sir i have query regarding e invoice…My turn over is 7cr but all sale is gst exempted can you kinldy help by telling that einvoice is applicable on nil rate gst for my sale…..kindly reply

    1. CA Sanjonaa Shetty says:

      Hello Gursimran Jit Singh,
      E invoice is not applicable on exempted and nil rated supplies.
      Since Exempted and nil rated supplies require bill of supply.

  11. CA Sanjonaa Shetty says:

    Would request viewers to WhatsApp for any queries at number 98336 31616 or better to post comments on this article.

    Would request you to please not call on the number 98336 31616.

    Thank you for your consideration.

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