E invoice missed out/not generated for FY2025-26

Back-dating e-invoices is strictly constrained by the IRP time limits; given the high invoice value, it is advised to check the portal immediately and seek professional guidance to mitigate potential non-compliance penalties.

E-invoices cannot be generated retrospectively once the cancellation window has passed (typically 24 hours from IRN generation for cancellation). There is no official back-dating mechanism on the IRP portal.

Here is what your options are:

1. PENALTY EXPOSURE: Under Rule 48(5) read with Section 122(3)(e), failure to generate e-invoice attracts a penalty of Rs 10,000 per invoice OR the tax involved on that supply, whichever is higher. If this is a large volume of invoices, the exposure can be significant.

2. ITC IMPACT ON YOUR BUYER: Your buyer cannot claim ITC on invoices that should have had an IRN but did not. This is now locked in via GSTR-2B. Your buyer may have received notices or may raise a dispute with you.

3. MITIGATION STRATEGY: Proactively disclose the non-compliance to your jurisdictional GST officer. Some field officers have accepted a detailed reconciliation statement showing the missed invoices, tax already paid on those supplies (GSTR-3B), and payment of the applicable penalty. This is not guaranteed but reduces the risk of a show cause notice with higher demands.

4. VOLUNTARY PENALTY PAYMENT: Under Section 73, you can pay the penalty voluntarily before receiving a notice. This limits further interest exposure.

Do not continue issuing invoices without IRNs in FY 2026-27 if your turnover still crosses the threshold (Rs 5 crore currently).

For help with the penalty assessment and officer communication, [Tax Garden GST compliance services](https://taxgarden.in/services) can assist with this end-to-end.