E-Invoicing Under GST in India: Rules, ₹5 Cr Turnover Limit, Applicability & Exemptions
Akash Kore
· Founder & Product Architect· 6 min read
E-invoicing under GST is no longer restricted to large conglomerates. In India, any business with an Aggregate Annual Turnover (AATO) exceeding ₹5 Crore in any preceding financial year since FY 2017-18 is legally mandated to report invoices to the Invoice Registration Portal (IRP) to generate an IRN and QR code.
Who is required to generate E-Invoices? The ₹5 Crore AATO threshold
The e-invoicing mandate under GST has phased down progressively from ₹500 Crore in 2020 to ₹100 Cr, ₹50 Cr, ₹20 Cr, ₹10 Cr, and currently ₹5 Crore (notified under CBIC Notification No. 10/2023-Central Tax).
If your business exceeded ₹5 Crore in aggregate turnover in ANY financial year from 2017-18 onward, e-invoicing becomes mandatory for all subsequent years, even if turnover falls below ₹5 Crore in the current year.
Applicability Matrix: B2B, B2C, Exports, and Bill of Supply
E-invoicing is mandatory for all taxable B2B (Business-to-Business) supplies of goods and services, supplies to SEZ developers/units (with or without payment of tax), deemed exports, export transactions, and commercial B2B Credit Notes / Debit Notes.
Crucially, is e-invoicing applicable for a Bill of Supply? The answer is NO. E-invoicing does NOT apply to a Bill of Supply (issued for exempt, nil-rated, or non-taxable goods). Furthermore, retail B2C (Business-to-Consumer) transactions and imports are also exempt from IRP e-invoicing.
Entities and sectors exempt from GST E-Invoicing
Regardless of turnover, the following entities are statutory exemptions under Rule 48(4) of the CGST Rules:
1. Special Economic Zone (SEZ) manufacturing and service units (Note: SEZ developers are not exempt).
2. Insurers, banking companies, and financial institutions (including NBFCs).
3. Goods Transport Agencies (GTA) supplying services in relation to transport of goods by road.
4. Suppliers of passenger transportation services.
5. Multiplex cinema exhibition ticket services.
6. Government departments and local authorities.
The consequences of issuing an invalid non-IRN invoice
Under Rule 48(5) of the CGST Rules, any invoice issued by an applicable supplier without an IRN and signed QR code is treated as legally INVALID. It has no legal existence in the eyes of GST authorities.
This has immediate consequences: the recipient cannot claim Input Tax Credit (ITC), the transport vehicle can be detained under Section 129 for moving goods without a valid tax document, and the supplier faces penalties of ₹10,000 or 100% of the tax due (whichever is higher) under Section 122.
Seamless GST Invoicing with Dyopact
Dyopact generates standardized, compliant tax invoice formats with all 16 mandatory fields prescribed under Rule 46 of the CGST Rules. Download our free GST Invoice Template or use our Online GST Calculator to compute CGST, SGST, and IGST breakdowns effortlessly.
Related Dyopact Tools & Templates
Frequently Asked Questions
What is the turnover limit for e-invoicing under GST?
The current threshold for mandatory e-invoicing is ₹5 Crore Aggregate Annual Turnover (AATO) in any preceding financial year since FY 2017-18.
Is e-invoicing applicable for Bill of Supply?
No. E-invoicing is not applicable for a Bill of Supply. It is only mandatory for taxable B2B tax invoices, export invoices, SEZ supplies, and B2B credit/debit notes.
Does e-invoicing apply to B2C transactions?
No. E-invoicing through the government IRP portal does not apply to B2C transactions. However, entities with turnover over ₹500 Crore must provide a dynamic UPI QR code on B2C invoices.
What is an IRN and how is it generated?
An IRN (Invoice Reference Number) is a unique 64-character hash generated by the Invoice Registration Portal (IRP) using the supplier's GSTIN, invoice number, and financial year.
Akash Kore
Founder & Product ArchitectArchitecting business document operating systems and automated billing workflows for Indian SMBs, agencies, and enterprises.