# E-Invoice: Generation Process & Applicability

## Why E-Invoicing?

E-invoicing brings automation, standardisation and authenticity to GST invoicing. Instead of you preparing the invoice in isolation, the invoice details are first reported to the Invoice Registration Portal (IRP), which validates and assigns a unique identity to it.

## Process of Generating an E-Invoice

Step 1 — Upload to IRP

Supplier uploads invoice details on the IRP in Form INV-01.

Step 2 — IRP returns authenticated invoice

The portal returns the invoice with:

Invoice Reference Number (IRN) — a unique 64-character hash
Digital signature of the IRP
QR Code

In the same flow, the portal:

Pushes data to the GST System → auto-populates supplier's GSTR-1 and recipient's GSTR-2A/2B
Pushes data to the E-Way Bill system → auto-creation of e-way bill (Part-A)

## When is E-Invoicing Mandatory?

A registered person must issue e-invoices if aggregate turnover in any preceding financial year (from 2017-18 onwards) exceeds ₹ 5 crores.

### Persons Specifically Exempt (must remember)

SEZ Units (note: SEZ developers are NOT exempt)
Insurer / Banking company / FI / NBFC
GTA supplying transport of goods by road
Supplier of passenger transportation service
Supplier of services by way of admission to cinematograph films in multiplexes
Government department / Local authority

## Key Practical Points

Aggregate turnover is computed PAN-wise (all GSTINs of the same PAN added together).
Even if recipient is registered only for TDS u/s 51, an e-invoice must still be issued (recipient is a 'registered person').
Once notified, applicability is permanent — you cannot exit even if turnover later drops.

Worked example

### Example 1

Example — Royal Pharma

Royal Pharma (pharmaceutical co.) has offices in Delhi and Mumbai. Turnover for FY 2022-23: Delhi ₹ 3 crores + Mumbai ₹ 4 crores.

(i) E-Invoicing requirement for FY 2025-26?

Aggregate turnover (PAN-level) = ₹ 3 cr + ₹ 4 cr = ₹ 7 crores (exceeds ₹ 5 cr threshold in a preceding FY). Therefore, both Delhi and Mumbai offices are liable to issue e-invoices.

(ii) If Delhi office is a SEZ unit?

SEZ units are specifically exempted from e-invoicing. Hence Delhi (SEZ unit) is exempt, but Mumbai continues to be liable.

(iii) If recipient is a Government department registered only for TDS u/s 51?

A TDS deductor is still a registered person. Therefore the supplier (Royal Pharma) is still required to issue an e-invoice.

⚠️ Common exam mistakes

Treating SEZ developers as exempt — only SEZ units are exempt; developers are covered.
Computing turnover GSTIN-wise instead of PAN-wise (aggregate turnover is across all GSTINs of the PAN).
Skipping e-invoice when recipient is registered only for TDS u/s 51 — e-invoice is still required.
Believing the obligation lapses when turnover later falls below ₹ 5 crores — once applicable, it continues.
Confusing IRP with GST portal — e-invoice is uploaded on IRP, not on the GST common portal.

Reference:

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E-Invoice Generation Process and Applicability

Worked example

⚠️ Common exam mistakes