E Invoice Effective Date

As per the GST regulations, e-invoicing is mandatory for businesses with a turnover exceeding ₹5 crores in a financial year.

Threshold Exceedance: Since your business has exceeded the ₹5 crore turnover threshold in the financial year 2024-25 (by November 2024), you are required to implement e-invoicing.

 Effective Date for E-Invoicing: The effective date for e-invoicing is the 1st day of the month immediately following the quarter in which the threshold is exceeded.

Applicable Quarter: In your case, the threshold was exceeded in the quarter October-December 2024. Effective Date: Therefore, you are required to implement e-invoicing from *January 1, 2025*.

Recommendation: To ensure compliance, prepare your system and processes to generate e-invoices from January 1, 2025.

 You can start testing and generating e-invoices on a voluntary basis from December 2024 to ensure a smooth transition. Important Note: Keep in mind that the GSTN (Goods and Services Tax Network) may announce changes to the e-invoicing regulations, so it's essential to stay updated with the latest notifications and guidelines.

Notification No. 70/2020-Central Tax, dated September 30, 2020, indeed makes an amendment to Notification No. 13/2020-Central Tax, dated March 21, 2020. According to the notification, the words "a financial year" are substituted with "any preceding financial year from 2017-18 onwards". This change affects the applicability of certain GST provisions.¹ ² To clarify, the amendment: - *Substitutes "a financial year" with "any preceding financial year from 2017-18 onwards"*: This change impacts the scope of the notification, making it applicable to preceding financial years starting from 2017-18. - *Amends Notification No. 13/2020-Central Tax*: The original notification was published on March 21, 2020, and was later amended by Notification No. 61/2020-Central Tax, dated July 30, 2020. The amendment is related to Rule 48(4) of the Central Goods and Services Tax Rules, 2017.

E-invoicing becomes mandatory from the first day of the month following the quarter in which your aggregate annual turnover crosses Rs.5 crore. For example, if you cross the threshold during July-September 2026, e-invoicing applies from October 1, 2026. The threshold is calculated on PAN-level aggregate turnover across all your GST registrations and across all financial years since 2017-18, not just the current year. Once applicable, you must generate IRN (Invoice Reference Number) for all B2B invoices, credit notes, and debit notes, there is no grace period after the effective date.

E-invoicing starts from the next financial year, not mid-year:

• Notf 13/2020-CT (as amended by Notf 70/2020 and 10/2023) covers a registered person whose aggregate turnover in any preceding FY from 2017-18 onwards exceeds Rs 5 crore. "Preceding" means a completed year.

• If AATO first crosses Rs 5 crore in FY 2024-25 (by November 2024), e-invoicing becomes mandatory from 1 April 2025. Not from December 2024.

• Aggregate turnover is PAN-based (all GSTINs under the same PAN, including exempt and export supplies, excluding taxes).

• Once applicable, it applies permanently, even if turnover later falls (Notf 13/2020 tests "any" preceding year).

• Exempt entities: SEZ units, insurers, banks, GTAs, passenger transport, multiplex cinemas. Also file the e-invoice exemption declaration if eligible.

• For AATO of Rs 10 crore and above, the 30-day IRN reporting limit also applies.