Comprehensive Summary of GST E-Invoicing Applicability

 

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.