1. General Applicability of E-Invoicing under GST
E-invoicing under GST is governed by Rule 48(4) of the CGST
Rules, 2017. It mandates certain registered taxpayers to generate invoices
through the Invoice Registration Portal (IRP).
·
Key Points:
·
• Applicable to businesses with aggregate
turnover of ₹5 crore or more in any financial year from 2017–18 onwards.
·
• Covers B2B transactions, exports, and
credit/debit notes.
·
• Not applicable to B2C invoices or exempted
entities.
·
Exemptions include:
·
• Banks, insurers, NBFCs, and financial
institutions
·
• Goods Transport Agencies (GTA)
·
• SEZ units (not developers)
·
• Government departments and local authorities
·
• Passenger transport services and cinema
admissions
2. Example Case: Business Starting in 2023–24
Turnover progression:
·
• FY 2023–24: ₹2 crore
·
• FY 2024–25: ₹3 crore
·
• FY 2025–26: Exceeds ₹5 crore
Conclusion: Since the turnover exceeds ₹5 crore in FY
2025–26, e-invoicing becomes applicable from FY 2026–27 (as the threshold is
based on any preceding financial year).
3. Key Notifications & Circulars
Notifications:
·
• Notification No. 13/2020 – Central Tax:
Introduced e-invoicing for turnover ≥ ₹100 crore from 1 Oct 2020.
·
• Notification No. 61/2020 – Central Tax:
Deferred implementation to 1 Oct 2020.
·
• Notification No. 70/2020 – Central Tax:
Reduced threshold to ₹500 crore.
·
• Notification No. 88/2020 – Central Tax:
Reduced threshold to ₹100 crore.
·
• Notification No. 05/2021 – Central Tax:
Reduced threshold to ₹50 crore.
·
• Notification No. 17/2022 – Central Tax:
Reduced threshold to ₹10 crore.
·
• Notification No. 10/2023 – Central Tax:
Current threshold ₹5 crore from 1 Aug 2023.
Circulars:
·
• Circular No. 186/18/2022-GST: Clarified
applicability for government departments registered for TDS.
·
• Circular No. 198/10/2023-GST: Clarified scope
of Rule 48(4) and exemptions.
4. Chronology of E-Invoicing Notifications
|
Notification No. |
Date |
Threshold & Applicability |
|
13/2020
– Central Tax |
21 Mar 2020 |
Introduced e-invoicing
for turnover ≥ ₹100 crore from 1 Oct 2020 |
|
61/2020 – Central Tax |
30 Jul 2020 |
Deferred implementation to 1 Oct 2020 |
|
70/2020
– Central Tax |
30 Sep 2020 |
Reduced threshold to
₹500 crore |
|
88/2020 – Central Tax |
10 Nov 2020 |
Reduced threshold to ₹100 crore |
|
05/2021
– Central Tax |
8 Mar 2021 |
Reduced threshold to
₹50 crore |
|
17/2022 – Central Tax |
1 Aug 2022 |
Reduced threshold to ₹10 crore |
|
10/2023
– Central Tax |
10 May 2023 |
Reduced threshold to
₹5 crore from 1 Aug 2023 |
5. Clarified Scope of Rule 48(4) and Exemptions
Rule 48(4) mandates notified taxpayers to generate invoices
through the IRP for B2B supplies, exports, and credit/debit notes.
·
Exemptions include:
·
• Government departments registered only for TDS
under GST (Section 51)
·
• Banks, insurers, NBFCs, and financial
institutions
·
• SEZ units (not developers)
·
• Goods Transport Agencies (GTA)
·
• Passenger transport services
·
• Admission to cinema halls
6. Practical Takeaways for Businesses and Government Departments
·
• E-invoicing applies to registered persons with
turnover exceeding ₹5 crore in any financial year since 2017–18.
·
• Applies to B2B transactions, exports, and
credit/debit notes only.
·
• B2C transactions are excluded.
·
• Government departments registered only for TDS
are exempt.
·
• Exemptions also apply to banks, insurers,
NBFCs, SEZ units, GTA, passenger transport, and cinema admissions.