E-Invoicing applicability

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This discussion clarifies e-invoicing applicability for GST registered taxpayers with multiple GSTINs across different states. E-invoicing is applicable if the aggregate turnover on a PAN basis exceeds ₹50 crore in any financial year from FY 2017-18 onwards. However, the turnover of a GTA providing services to others is not included when checking e-invoicing applicability for other GSTINs under the same PAN. Additionally, provisions of e-invoicing are not applicable to GTAs themselves.

Pragati Sharma

Pragati Sharma (Querist)

10 April 2021 A GST registered Taxpayer is having multiple GSTIN in different states.

Aggregate Turnover PAN basis:
FY 2017-18 - 60 Cr
FY 2018-19 - 62 Cr
FY 2019-20 - 72 Cr

One of the GSTIN whose turnover is Rs. 50 crore in each FY is a GTA. The GTA is providing both road and rail transport.

Query:
1. Whether e-invoicing will be applicable?
2. Whether we will look into average turnover from FY 2017-18 to 19-20 or if turnover over exceeds Rs. 50 crore in any of the FY from 17-18 to 19-20 will also make e-invoicing applicable?
3. Whether the turnover of GTA will be inlcluded while checking the applicability for all the GSTIN?

CMA Poornima Madhava

CMA Poornima Madhava (Expert)

10 April 2021 1) Yes, applicable.
2) e-invoicing provisions are applicable if the aggregate turnover in any of the FY starting from FY17-18, exceed ₹50 lacs.
3) No. Aggregate turnover shall not include inward supplies subject to RCM.

Provisions of e-invoicing are not applicable to GTAs.

Pragati Sharma

Pragati Sharma (Querist)

12 April 2021 One of the GSTIN under the PAN is a GTA service Provider.

For calculating aggregate turnover we have to include the turnover of GTA also for checking the e invoice applicability?

CMA Poornima Madhava

CMA Poornima Madhava (Expert)

12 April 2021 Is the GTA service provider to you or are you the GTA providing service to others?

Pragati Sharma

Pragati Sharma (Querist)

15 April 2021 GTA providing services to others

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