GTA Service under E Invoice

Hi Anshuman,

Your query relates to e-Invoicing applicability when your business has mixed supplies — one under RCM (GTA services) and the other under Forward Charge (Container Handling Services).

Let’s break it down point by point:

🔹 1. Are you eligible for e-Invoicing?

✅ Yes.

As your aggregate turnover exceeded ₹10 Cr (now ₹5 Cr) in FY 2019–20, you fall under the mandatory e-invoicing provisions (Section 16 of CGST Rules, read with Rule 48(4)) — if your outward supplies are taxable under forward charge.

Since your Container Handling Services are under Forward Charge, e-Invoicing is applicable for that part of your business.

🔹 2. Which services require e-Invoice?

Business Type	Charge Mechanism	E-Invoicing Required?	Reason
GTA Services (SAC 9965)	RCM	❌ No	E-Invoicing not applicable to services attracting RCM, even if turnover is above the threshold.
Container Handling (SAC 996711)	Forward Charge	✅ Yes	Taxable under forward charge; hence e-Invoicing is mandatory.

🔸 So you must generate e-Invoices only for the Container Handling Services.

🔹 3. Legal Reference & Sections

Here are the relevant rules and notifications:

✅ Rule 48(4) of CGST Rules, 2017:

"The invoice shall be prepared by such class of registered persons as may be notified by the Government, by including such particulars contained in FORM GST INV-01... and after obtaining an Invoice Reference Number (IRN)."

✅ Notification No. 13/2020 – Central Tax, dated 21.03.2020:

Specifies turnover threshold (₹500 Cr then, reduced via further notifications to ₹5 Cr as of 01.08.2023).

✅ Exemptions from e-Invoicing:

As per Notification No. 13/2020 read with Notification No. 23/2021, e-Invoicing is not applicable to:

SEZ units,
Insurance,
Banking, NBFC,
GTA (under RCM),
Passenger transportation,
Admission to exhibition of cinematograph films.

So, GTA services under RCM are explicitly exempt from e-Invoicing — even if the service provider crosses the turnover threshold.

✅ Conclusion

Yes, you are eligible for e-Invoicing as your turnover exceeds ₹10 Cr.
e-Invoicing is required only for Container Handling Services (forward charge).
GTA services (RCM) are exempt from e-Invoicing, as per government notifications.

Let me know if you want a sample e-Invoice JSON format or the link to NIC portal for testing.