## E-Invoicing for Invoices, Debit & Credit Notes

### What is E-Invoicing?

E-invoicing does NOT mean generating invoices on the government portal. It means reporting the invoice on the government portal called the Invoice Registration Portal (IRP), which then assigns an IRN (Invoice Reference Number) to it.

### Applicability of E-Invoicing

E-invoicing is applicable when BOTH the following conditions are met:

1. Supplier is a 'notified person' — i.e., registered person with aggregate turnover > ₹5 crore in any preceding FY from 2017-18 onwards.

2. The supplies are:

B2B supplies, OR
Exports (export even to unregistered persons is covered).

Note: If a person is registered only for TDS deduction u/s 51, supplies to such person are treated as B2B, and e-invoice is required.

### When E-Invoicing is NOT Applicable

E-invoicing does not apply to the following suppliers (even if turnover exceeds ₹5 cr.):

Input Service Distributor (ISD)
SEZ units (Note: SEZ developers are NOT excluded — they must issue e-invoice)
Insurer, Banking Company, Financial Institution including NBFC
GTA for transport of goods by road
Passenger transportation services suppliers
Persons supplying services by way of admission to exhibition of cinematograph films in multiplex cinemas
Government department or local authority

Important: These exempt persons must give a declaration on the invoice that their turnover exceeds the prescribed amount in any FY from 2017-18, but they are not required to generate e-invoice.

### E-Invoicing under RCM

Scenario	E-Invoice Required?
Supplier is a notified person	Applicable (supplier issues e-invoice)
Supplier is unregistered & recipient is notified person	Not Applicable (recipient issues self-invoice, but not e-invoice)

### Amendment and Cancellation of E-Invoice

Amendment: Once uploaded, e-invoice can be amended only while filing GSTR-1.
Cancellation: Seller can cancel IRN by reporting on IRP within a specified time.

### Consequences of Non-Compliance

If e-invoicing is applicable but:

E-invoice is NOT issued, OR
E-invoice is issued but IRN is NOT mentioned on it

Then the document is treated as NO INVOICE ISSUED. Consequently:

Recipient cannot avail ITC even though a normal-looking invoice was issued.

Worked example

### Example 1

Example 1: ABC Ltd. has aggregate turnover of ₹8 crore in FY 2022-23 and ₹4 crore in FY 2023-24. Is e-invoicing required for FY 2024-25?

Answer: Yes. Turnover exceeded ₹5 crore in any preceding FY from 2017-18 onwards (FY 2022-23 qualifies). So e-invoicing applies.

### Example 2

Example 2: XYZ Bank (turnover > ₹5 crore) issues an invoice for banking services to a corporate customer. Is e-invoicing required?

Answer: No. Banking companies are exempt from e-invoicing, regardless of turnover. However, they must declare on the invoice that their turnover exceeds the threshold.

### Example 3

Example 3: PQR Ltd. (turnover ₹10 cr.) issues a normal tax invoice to a B2B customer but does not get an IRN. Can the recipient claim ITC?

Answer: No. Without IRN on the e-invoice, the document is treated as if no invoice was issued. The recipient cannot avail ITC.

### Example 4

Example 4: M/s X (unregistered) supplies goods under RCM to M/s Y (notified person, turnover ₹20 cr.). Y issues self-invoice. Must Y generate e-invoice for this self-invoice?

Answer: No. When the supplier is unregistered, even if the recipient is a notified person, e-invoicing under RCM is not applicable.

### Example 5

Example 5: An SEZ unit (turnover ₹8 cr.) makes a B2B supply. E-invoice required?

Answer: No. SEZ units are exempted (though SEZ developers are required to issue e-invoice).

### Example 6

Example 6: An ABC Co. (turnover ₹10 cr.) supplies to LMN Co. which is registered only for TDS purposes u/s 51. E-invoice required?

Answer: Yes. Supply to TDS-only registered person is treated as B2B; e-invoice is required.

⚠️ Common exam mistakes

Confusing 'e-invoice generation' with reporting on IRP — it is reporting, not direct generation on the portal.
Applying the ₹5 crore threshold to the current year only — it applies to ANY preceding FY from 2017-18.
Treating SEZ developers as exempt — only SEZ units are exempt; developers must issue e-invoice.
Issuing tax invoice without IRN but assuming ITC is still available to recipient — without IRN, no ITC.
Believing B2C invoices require e-invoicing — only B2B and exports require it.
Confusing supplier exemptions (banks, GTA, multiplexes, etc.) — these don't issue e-invoices regardless of turnover, but must declare on invoice.
Forgetting that exports to unregistered persons also require e-invoicing.
Missing the rule that supplies to TDS-only registered persons are B2B for e-invoicing purpose.

Reference: Rule 48(4) — CGST Rules, 2017

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E-Invoicing — Applicability, Exceptions and RCM

Worked example

⚠️ Common exam mistakes