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.
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could you please confirm is e-invoice required for doing job work? We are 20 crore turnover company and following e-invoices for our clients.
Hello one of my client turnover crossed 5 cr in Jan 2024 .So he started issuing e-invoices from Jan 2024 only instead of April 2024 .Will there be any issue .
Can ITC be disallowed to recipient for the period of April 2023 to Dec 2023 .Since mandate provision applies on him from 1St April 2024 . Basically he started doing voluntary e-invoicing from 1st Jan since turnover exceeds 5 cr
As my turnover was above 5 cr in 17-18 i was eligible for issuing e-invoice from 1-08-23. i made some sales in the month of jan 24 and feb 24 for which i did not generated e-invoice.
Today i got a email that I have been enabled for einvoice. from now on I will issue e-invoice.What will be the remedy for not issuing previous 3 bills
Hi Sandeep,
Yes you are right you were eligible for e invoicing from 1st Aug 23. Now for the bills generated on Jan and Feb 24 you may either raise credit notes in March and generate invoice in the month of march .
But you will have to generate e-invoice for the credit notes as well
We have not crossed the limit of Rs 5 Cr in any previous years also in the current year so far. We want to sale goods of gross value of Rs. 70000/-. Do we need to generate e-invoice?
Hello Pradeep,
There is no need to generate e-invoice. Once your turnover crosses 5 cr ,then e-invoicing will be applicable in the next F.Y
CAN WE GENERATE E-INVOICE FOR OTHER STATE PARTY AFTER 15 DAYS OF INVOICE GENERATE ?
Hello Birendra,
The GST advisory has been issued for GSTIN with 100 crore turnover that invoice has to be issued within 30 days .
No advisory is issued for turnover less than 100 crore
CAN WE GENERATE E-INVOICE FOR OTHER STATE PARTY ?
Dear madam,
E-Invoice Note Received From Supplier Normal Tax Invoice Received Kindly Confirm me ITC take on Normal Tax Invoice
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!
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
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.
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.
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
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.
Sir,
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?
Sir,
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
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
Is e-invoicing is applicable for service recipient (Regular Registered Entity) on RCM if self invoice issued.
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
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
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.
in the export case e invoice applicable or not pls tell me
Hello Prem Kumar,
E-invoicing is applicable to export supplies .
Check point Supplies and Documents for your clarification.
Thank you.
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
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.
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 ?
Hi Somex,
If your turnover exceeds 5 crore then e-invoicing is applicable for job work processing charges
does interest income received from unsecured loans include in the aggregate turnover?
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.
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
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.
Hello,
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Thank you for your consideration.