Non-GST invoices and GST payment

Invoice Compliance: A domestic service provider cannot continue issuing non-GST invoices after crossing the ₹20 Lakh threshold. They must apply for registration within 30 days and eventually issue Revised Tax Invoices for the interim processing period.

Retrospective Tax Demand: Yes, the supplier can demand the tax retrospectively. Section 31(3)(a) allows them to issue revised invoices within 1 month of getting their registration certificate to regularize past transactions.

Compelling the Exporter: The GST department holds the supplier liable, not the recipient. However, the exporter should commercially pay the retrospective tax only if the supplier provides a valid Revised Tax Invoice that allows the exporter to successfully claim Input Tax Credit (ITC) and a subsequent export refund.

Issuance of Non-GST / Pro Forma Invoices Post Threshold: Can a service provider continue issuing non-GST or pro forma invoices for more than six months after crossing the ₹20 lakh threshold, solely on the ground that GST registration was delayed by the department?

Revised Tax Invoices for Past Services: Is it permissible for a service provider to issue revised tax invoices for services rendered four to five months earlier? If so, is there a statutory time limit within which such revised tax invoices must be issued after obtaining GST registration, calculated from the date of the original non-GST or pro forma invoice?

Retrospective Regularization of Invoices: With respect to retrospective tax demand, how far back can non-GST or pro forma invoices be revised into GST-compliant tax invoices? For instance, can invoices that are three to four months old be revised, or is the revision restricted to invoices within one month? Is there a prescribed time limit for such regularization?

GST Liability in Absence of Refund Claim: If the service exporter is not claiming any GST refund, can the service provider nevertheless compel the service exporter to bear and pay GST liability for the period prior to registration?