‘e-Invoicing’ or ‘electronic invoicing’ is a system in which B2B invoices and a few other documents are authenticated electronically by GSTN for further use on the common GST portal.
Under the electronic invoicing system, an identification number will be issued against every invoice by the Invoice Registration Portal (IRP), managed by the GST Network (GSTN). The National Informatics Centre launched the first IRP at einvoice1.gst.gov.in.
All invoice information gets transferred from this portal to both the GST portal and the e-way bill portal in real-time. Therefore, it eliminates the need for manual data entry while filing GSTR-1 returns and generation of part-A of the e-way bills, as the information is passed directly by the IRP to the GST portal.
The e invoice applicability can be explained as follows-
Turnover criteria or e Invoice limit
Phase | Applicable to taxpayers having an aggregate turnover of more than | Applicable date | Notification number |
I | Rs 500 crore | 01.10.2020 | 61/2020 – Central Tax and 70/2020 – Central Tax |
II | Rs 100 crore | 01.01.2021 | 88/2020 – Central Tax |
III | Rs 50 crore | 01.04.2021 | 5/2021 – Central Tax |
IV | Rs 20 crore | 01.04.2022 | 1/2022 – Central Tax |
V | Rs 10 crore | 01.10.2022 | 17/2022 – Central Tax |
VI | Rs 5 crore | 01.08.2023 | 10/2023 - Central Tax |
QPR ltd should also comply with e-Invoicing from 1st August 2023 since its annual turnover exceeds Rs.5 crore in FY 2020-21
As per GST law, “aggregate turnover” refers to the aggregate value of all taxable supplies (excluding the value of inward supplies on which tax is payable by a person on reverse charge basis), exempt supplies, exports of goods or services or both and inter-state supplies of persons having the same Permanent Account Number, to be computed on an all-India basis but excludes Central tax, State tax, Union territory tax, Integrated tax and cess.
The aggregate turnover computed for the entire financial year between April of a year up to March of next year is called annual aggregate turnover. In other words, it is the total turnover calculated at a PAN Level (all GSTINs put together) being sum of the following:
However, the above sum excludes the tax components such as the Central tax, State tax, Union territory tax, Integrated tax and Cess. Further, the taxable value excludes those purchases where the person is required to pay tax under reverse charge. Note that the sales that are subject to reverse charge must continue to form part of the taxable supplies in aggregate turnover.
Until 30th April 2023, there has been no time limit fixed by the GST systems or the GST law to generate e-invoices. From 1st May 2023* onwards, taxpayers with Annual Aggregate Turnover (AATO) equal to or more than INR 100 crore must generate e-invoices for tax invoices and credit-debit notes within 7 days of invoice date, failing which such invoices and CDNs will be considered non-compliant.
Further, there is no defined time limit or period within which e invoice must be generated for the rest of the applicable taxpayers. Therefore, such taxpayers are advised to create e invoice on or after the invoice/CDN date preferably a week before the filing of GSTR-1 returns since it takes T+3 days for details of e-invoices to get auto-populated into GSTR-1.
*However, on 6th May 2023, the department has deferred the time limit of 7 days to report the old e-invoices on the IRP portals by three months. Also, the department is yet to announce the new implementation date
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