E-invoice and recent circular under GST

Every registered taxable person whose aggregate annual turnover exceeds Rs. 10 Cr in any of the financial year starting from 2017-18 is liable to issue e-invoice by way of uploading its tax invoice in json file on Invoice Registration Portal (IRP) in accordance with e-invoice schema in INV-01 and getting back digitally signed json from IRP with IRN and QR Code.

E-invoice is required to be issued for business-to-business (B2B) supplies and export of goods and services.

The following documents are covered under e-invoice:

Tax Invoice
Debit Note
Credit Note

The following registered persons are exempted from e-invoicing:

Insurance, Banking or Financial Institution including NBFC
Goods Transport Agency transporting goods by road
Supplier of passenger transportation service
Person supplying services by of admission to exhibition of cinematographic film in multiplex screen
SEZ Unit

Government vide Circular No 186/18/2022-GST dated 27 December 2022 clarified that exemption from mandatory generation of e-invoice is available for the entity as whole. The relevant extract is reproduced below:

Issue	Clarification
Whether the exemption from mandatory generation of e-invoices in terms of Notification No. 13/2020-Central Tax, dated 21stMarch, 2020,as amended, is available for the entity as whole, or whether the same is available only in respect of certain supplies made by the said entity?	In terms of Notification No. 13/2020-Central Tax dated 21stMarch, 2020, as amended, certain entities/sectors have been exempted from mandatory generation of e-invoices as per sub-rule (4) of rule 48 of Central Goods and Services Tax Rules, 2017. It is hereby clarified that the said exemption from generation of e-invoices is for the entity as a whole and is not restricted by the nature of supply being made by the said entity. Illustration: A Banking Company providing banking services, may also be involved in making supply of some goods, including bullion. The said banking company is exempted from mandatory issuance of e-invoice in terms of Notification No. 13/2020-Central Tax, dated 21stMarch, 2020,as amended, for all supplies of goods and services and thus, will not be required to issue e-invoice with respect to any supply made by it.