When an exporter need to generate e-invoice?

For exporters in India, e-invoicing is a mandatory requirement under the GST framework, provided specific criteria are met. Here is a summary of the rules and requirements:

1. Applicability (Who needs to generate it?)

• Turnover Threshold: E-invoicing is mandatory if your aggregate annual turnover (AATO) has exceeded ₹5 crore in any financial year from 2017–18 onwards.

• PAN-Based Calculation: This threshold is calculated on a PAN-wide basis (all-India turnover across all GST registrations linked to that PAN).

• Scope: If you meet the threshold, you must generate e-invoices for all export transactions (whether of goods or services), regardless of whether the export is with or without payment of tax (i.e., including exports under LUT/Bond).

2. Key Requirements for Export E-Invoices

When generating an e-invoice for an export, you must ensure the following:

• Supply Type: You must mark the supply type as "EXP" (Export).

• Export Category: Clearly specify if it is "Export with payment" or "Export under LUT/Bond without payment."

• Mandatory Data: Even though the foreign recipient is not registered under Indian GST, you must include their full business name, address, country, and any available international tax identification number.

• Shipping Details: If available, include the shipping bill number and date.

3. Reporting Timeline

• General Requirement: For most businesses, it is best practice to generate the e-invoice on or after the invoice date but before the filing of GSTR-1 returns.

• 30-Day Limit: For taxpayers with an AATO of ₹10 crore and above, there is a strict time limit: you must report the invoice to the Invoice Registration Portal (IRP) within 30 days of the invoice date. Failing to do so renders the invoice non-compliant.

4. Consequences of Non-Compliance

• Invalid Invoice: An invoice without a valid Invoice Reference Number (IRN) and the digitally signed QR code is considered invalid under GST law.

• Penalties: Failure to generate a valid e-invoice can attract penalties under Section 122 of the CGST Act (up to ₹10,000 or 100% of the tax due, whichever is higher, per invoice).

• Refund Impact: For exporters, missing e-invoicing can delay or lead to the rejection of IGST or Input Tax Credit (ITC) refunds, as customs and tax authorities rely on data alignment between the IRP and the ICEGATE/GST systems.