Who are liable to generate e-invoice w.e.f 1st Oct 2022



Quick Summary
The Goods and Services Tax (GST) Council introduced e-invoicing in a phased manner, with the requirement initially applying to businesses with an aggregate turnover of INR 500 crore and above from October 1st, 2020. This threshold has been progressively reduced. As of October 1st, 2022, businesses with an aggregate turnover exceeding INR 10 crore are required to generate e-invoices.

The GST Council, in its 37th meeting held on 20.09.2019, has recommended introduction of electronic invoice ('e-invoice') in GST in a phased manner. E-invoicing was initially made applicable w.e.f  01.10.2020 for the registered person having aggregate turnover of Rs. 500 crore and above only.

Since then, aggregate turnover is being reduced in a phased manner so as to cover maximum taxpayers under the e-invoicing in following manner:

E-Invoice Generation: Who Needs to Comply from Oct 2022

Phases

Applicable to taxpayers having aggregate turnover of more than

W.e.f.

Notification No.

1.

INR 500 crore

01.10.2020

Notification No. 61/2020- Central Tax dated 30.07.2020

2.

INR 100 crore

01.01.2021

Notification No. 88/2020–Central Tax dated 10.11.2020

3.

INR 50 crore

01.04.2021

Notification No. 05/2021–Central Tax dated 08.03.2021

4.

INR 20 crore

01.04.2022

Notification No. 01/2022- Central Tax dated 24.02.2022

5.

INR 10 crore

01.10.2022

Notification No. 17/2022–Central Tax dated 01.08.2022

Notes:

 
  • E-invoicing provisions are applicable when the stated aggregate turnover threshold limits crosses in any of previous financial year(s) starting from FY 2017-18. Thus, aggregate turnover limit of current financial year is not to be considered.
  • Certain Entity are not required to generate e-invoicing even though their annual aggregate turnover crosses specified limit viz. SEZ units (not developer), insurer or banking company or financial institution, GTA, passenger transport service provider and invoicing in case of services by way of admission to exhibition of cinematograph films in multiplex screens, a government department, a local authority.
  • Applicable only for B2B Taxable Supplies of Goods or Services or both, DN/ CN, Exports.
  • Not Applicable for B2C Supplies, Exempted Supplies (Bill of Supply), Receipt Voucher (on advance received for supply of services), Refund Voucher (Refund of advance money received), Payment Voucher & Self-Invoice (for RCM liability received from unregistered person), ISD Invoice.
 

Compliance

The registered person to whom e-invoicing is applicable have to generate tax invoice with specified particulars as per e-schema INV-01 from taxpayer's own account and billing software, then convert the same into JSON file, and transmit such file on dedicated Invoice Registration Portal ("IRP") launched by the Government.

Subsequently, IRP will generate unique e-invoice reference number with Quick Reference ("QR") Code and digitally signed JSON file and send it to the concerned supplier and will also push the data to GST Portal for auto population of date in GSTR-1 (outward supply statement) and E-waybill portal for generation of e-way bill.

FAQ :

Initially, from 1st October 2020, only registered persons with an aggregate turnover of INR 500 crore and above were required to generate e-invoices.

From 1st October 2022, taxpayers having an aggregate turnover of more than INR 10 crore are liable to generate e-invoices.

The aggregate turnover limit applies if it was crossed in any of the previous financial years starting from FY 2017-18. The current financial year's turnover is not considered.

Yes, certain entities are exempt even if they cross the turnover limit. These include SEZ units (not developers), insurers, banking or financial institutions, GTAs, passenger transport service providers, and government departments or local authorities.

E-invoicing is applicable only for B2B taxable supplies of goods or services, debit notes, credit notes, and exports.

Businesses generate a tax invoice with specified particulars using their own software, convert it to JSON, and transmit it to the Invoice Registration Portal (IRP). The IRP then generates a unique e-invoice reference number and QR code.


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About the Author

Service

FCA, FCS LLB with21 Yrs of Experience inTaxation Indirect and Direct: Education Qualification: B.Com (Hons) Chartered Accountants Company Secretary LLB Qualified SAP FI/CO Consultants Professional Membership: Chairmanof Indirect Tax Committee of PHD Chamber of Commerce Member of Indirec ... Read more


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