We have doing two type of business in same PAN no.
1st Business is GTA services Provider (RCM basis)
2nd is Container Handling Services (Forward Charge Basis)
We have a turn over more than Rs 150/- Cr. in 19-20 FY.
We know Goods Transport Agency (GTA) by road are exempted from the e-Invoicing process.
But Container Handling Services are in following the e-Invoicing process.
Every month we make two type of Invoice one is GTA services Provider and 2nd is Container Handling Services’ SAC Code 996711.
Now question is 1/Whether we are eligible for E Invoice?
2/ If yes, then which part of our business is fall to make e invoice GTA or Container services provider?
3/Please provide the section ?
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GTA Service under E Invoice
Replies (1)
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.
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