Can we E invoices now form August 2023 to March 2024?


This query is : Resolved 

Quick Summary
A business with a turnover of over £10 crore for 2022-23 issued manual invoices from August 2023 to March 2024 instead of e-invoices. They are asking if they can generate e-invoices for these past transactions now. The advice given is that retrospective e-invoicing is not permitted as the GST portal does not allow backdated generation beyond a few days. Invoices issued without an e-invoice number are invalid, potentially preventing buyers from claiming Input Tax Credit (ITC) and risking penalties. It's recommended to inform buyers, consult a GST professional, and ensure future compliance.

15 April 2024 Sir/Madam
Turnover for the financial year 2022-23 is Rs. 10.10 Crores. From August 2023 we have not generated e invoices but manual invoices provided to buyers and filed GSTR 1 and GSTR3B.

Can we generate e invoices now for all the invoices for which manual invoices raised earlier( August 2023 to March 2024).

Thanks in advance.


16 April 2024 In my opinion, you should not raise e-invoice because:
1)You have already issued non e-invoice bills to parties
2) Transactions are already completed
3)GSTR1 has already been filed

13 August 2025 No, you cannot generate e-invoices now for backdated invoices.
Why?
The GST e-invoice portal (IRP) does not allow backdated invoice generation.
Once the invoice date is older than 7 days (some IRPs even stricter), you cannot generate an e-invoice for that date.
E-invoicing must be done before or at the time of invoice issuance.
⚠️ Implications of Non-Compliance
Invoices issued without IRN (e-invoice number) are not valid under law.
Your B2B buyers technically cannot claim ITC on those invoices.
There is a risk of penalty under:
Section 122 of CGST Act – up to ₹25,000 per invoice
In audits, you may be asked to:
Pay penalties
Explain discrepancies
Rectify via revised documentation (if possible)
✅ What You Should Do Now
Identify all affected invoices from Aug 2023 to Mar 2024
Inform buyers about the non-compliance if ITC is in question
Consult your GST officer or CA to handle:
Voluntary disclosure
Possible penalty mitigation
Ensure strict compliance from April 2024 onward
E-invoice generation before issuing invoice
System integration with IRP for real-time compliance
❓ Can You Cancel and Reissue Invoices?
No, GST law does not permit reissuing old invoices with new dates just to enable e-invoice generation
That would amount to misreporting and may cause further complications
🔁 Going Forward – Best Practices
Automate e-invoice generation in your billing software
Set alerts when crossing turnover thresholds
Keep invoice generation real-time to avoid this issue again


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