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GST · Registration & returnsGST e-invoicing applicability: turnover, exemptions and IRN process
If your aggregate turnover crossed ₹5 crore in any year since 2017-18, every B2B invoice must be registered on the Invoice Registration Portal for an IRN. Here is who is covered, what is exempt, the process and the 30-day limit for larger taxpayers.
E-invoicing does not mean creating invoices on a government portal. You create the invoice in your own software and report it to the Invoice Registration Portal (IRP), which validates it and returns an Invoice Reference Number (IRN) and a signed QR code. The data flows automatically to GSTR-1 and the e-way bill system.
Who is covered
| Test | Rule |
|---|---|
| Turnover | Aggregate turnover (PAN-level, all-India) exceeded ₹5 crore in any financial year from 2017-18 |
| Once covered | Continues even if turnover falls later |
| Supplies | B2B, exports, SEZ supplies, deemed exports, supplies under reverse charge to registered persons |
| Documents | Tax invoices, credit notes, debit notes |
Exempt entities
- SEZ units (not developers);
- Insurance companies, banks, financial institutions, NBFCs;
- Goods transport agencies;
- Passenger transport service suppliers;
- Suppliers of admission to cinema (multiplex);
- Government departments and local authorities (as notified).
The process
- Create the invoice in your ERP/accounting software in the prescribed schema.
- Upload JSON to the IRP (directly, through GSP/API, or via the free offline/online tools).
- IRP validates (GSTIN, duplicate check) and returns IRN, acknowledgement number and signed QR.
- Print/share the invoice with QR code.
- Data auto-populates GSTR-1 and can generate the e-way bill (Part A).
Time limits
- No time limit in law for reporting generally, but for taxpayers with aggregate turnover ₹10 crore and above, invoices older than 30 days cannot be reported (from 1 April 2025). Credit/debit notes also covered.
- Cancellation of an IRN within 24 hours; after that, issue a credit note.
Worked example
Example: Pixelgrid Infotech Pvt Ltd had turnover of ₹4.6 crore in FY 2023-24 and ₹5.3 crore in FY 2024-25.
- Since aggregate turnover exceeded ₹5 crore in FY 2024-25, e-invoicing applies from 1 April 2025.
- All B2B invoices from April 2025 need IRN; an invoice issued on 10 June 2025 without IRN is invalid – buyers' ITC is at risk.
- If turnover falls to ₹4 crore in FY 2025-26, e-invoicing still applies.
- Its turnover is below ₹10 crore, so the 30-day restriction does not apply (but late reporting is still poor practice).
Example 2: A manufacturer with turnover of ₹14 crore issues an invoice dated 1 August 2026 and tries to report it on 5 September 2026 – the IRP rejects it (beyond 30 days). The supplier must issue a fresh invoice with a new date, which changes the time of supply and may attract interest.
Practical checklist
- Check turnover of every year since 2017-18 (PAN-level, all States).
- Enable e-invoicing in your accounting software (Tally, Busy, Zoho support it).
- Map HSN codes correctly; validate buyer GSTINs.
- Train staff to generate IRN before dispatch.
- Reconcile IRP data with GSTR-1 monthly.
Penalties
- Invoice without IRN: penalty under Section 122 – ₹10,000 or tax evaded, whichever is higher.
- Incorrect invoicing particulars: penalty up to ₹25,000 under Section 125.
- Goods moving with a non-IRN invoice where required can be detained.
Common mistakes
- Checking only current-year turnover.
- Excluding other-State GSTIN turnover from aggregate turnover.
- Reporting B2C invoices unnecessarily or missing export invoices.
- Missing the 30-day window for ₹10 crore+ businesses.
Key takeaway
If you ever crossed ₹5 crore aggregate turnover since 2017-18, generate IRNs for all B2B invoices and notes, within 30 days if you are at ₹10 crore or more. Our GST compliance team helps set up e-invoicing and monthly IRP reconciliations.
Official references
Provisions discussed (summaries in our Law Library):
- CGST Rules, 2017 – Section 48(4): E-invoicing
Official sources to verify the current text, notifications and circulars:
Frequently asked questions
Who must issue e-invoices?
Registered persons whose aggregate turnover in any financial year from 2017-18 onwards exceeded ₹5 crore, for B2B supplies, exports and certain other documents.
Is e-invoicing required for B2C invoices?
No. B2C invoices are outside e-invoicing, though very large taxpayers (above ₹500 crore) must show a dynamic QR code on B2C invoices.
What is the 30-day rule?
Taxpayers with aggregate turnover of ₹10 crore or more cannot report invoices to the IRP more than 30 days after the invoice date (from 1 April 2025; earlier ₹100 crore).
What happens if an e-invoice is not generated?
An invoice without IRN, where required, is not a valid invoice. The buyer cannot claim ITC and the supplier may face penalty of 100% of tax due or ₹10,000, whichever is higher.
Do exports need e-invoices?
Yes. Export invoices of e-invoicing taxpayers must be reported to the IRP.
Is e-invoicing needed for credit notes to B2C customers?
No. B2C documents are outside e-invoicing.
Can e-invoices be generated for free?
Yes. The government's IRP portals and offline tools are free; many accounting packages integrate directly.
This article is general information on the law as on 10 November 2026, written for educational purposes. It is not professional advice for your case. Section numbers under the Income-tax Act, 2025 should be confirmed with the official section mapping on the Income Tax Department website before use in filings.
Have a tax, GST or business question?
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