From the Knowledge Centre
GST e-invoicing applicability: ₹5 crore limit and 30-day rule
GST e-invoicing is mandatory for a registered person whose aggregate turnover, computed on a PAN basis, has exceeded ₹5 crore in any financial year from 2017-18 onwards. Such a supplier must report each B2B invoice, credit note and debit note to an Invoice Registration Portal (IRP) and obtain an Invoice Reference Number (IRN) and QR code. If annual aggregate turnover (AATO) is ₹10 crore or more, the document must also be reported within 30 days of its date.
What is the current e-invoicing turnover limit?
The limit was brought down in stages under Rule 48(4) of the CGST Rules, 2017. The present limit of ₹5 crore has applied since 1 August 2023 under Notification No. 10/2023-Central Tax dated 10 May 2023.
| Aggregate turnover exceeding | Notification (Central Tax) | Applicable from |
|---|---|---|
| ₹500 crore | 61/2020 | 1 October 2020 |
| ₹100 crore | 88/2020 | 1 January 2021 |
| ₹50 crore | 5/2021 | 1 April 2021 |
| ₹20 crore | 1/2022 | 1 April 2022 |
| ₹10 crore | 17/2022 | 1 October 2022 |
| ₹5 crore | 10/2023 | 1 August 2023 |
How is the ₹5 crore test applied?
Three points decide whether a business is covered:
- PAN-wise turnover. Aggregate turnover is computed for all GSTINs registered under the same PAN, across all states. A branch with small sales in one state is covered if the PAN as a whole has crossed the limit.
- Any year since 2017-18. It is enough that the limit was exceeded in any one financial year from 2017-18. A business that crossed ₹5 crore in 2022-23 remains covered even if its turnover is lower today.
- No cut-off for a fall in turnover. Once covered, the obligation continues unless the business falls in an exempt class.
When a business first crosses the limit during a year, it should check its status on the e-invoice portal and prepare its billing software, because invoices issued without an IRN after coverage begins are not valid tax invoices.
Which supplies and documents need an e-invoice?
The e-invoice system accepts three document types from the supplier: the tax invoice, the credit note and the debit note. The supply types covered are:
| Covered | Not covered |
|---|---|
| B2B supplies to registered persons, including government buyers registered under GST | B2C supplies to unregistered consumers |
| Supplies to SEZ units and developers (with or without payment of tax) | Bill of supply |
| Exports (with or without payment of tax) | Delivery challans, including job-work challans |
| Deemed exports | Import documents |
A B2B tax invoice issued by a covered supplier is valid only with a valid IRN. Under Rule 48(5) of the CGST Rules, an invoice issued in any other manner is not treated as an invoice. This matters to the buyer too, because input tax credit depends on holding a valid tax invoice. Penalty provisions under the CGST Act can also apply to the supplier.
Who is exempt from e-invoicing?
Notification No. 13/2020-Central Tax, as amended, excludes certain classes of registered persons, whatever their turnover. The e-invoice portal lists them in its exemption declaration:
- Special Economic Zone units (SEZ developers are not exempt)
- Insurers
- Banking companies
- Financial institutions, including non-banking financial companies
- Goods transport agencies supplying road transport of goods
- Suppliers of passenger transportation services
- Suppliers of services by way of admission to exhibition of films in multiplex screens
- Government departments
- Local authorities
An exempt entity whose GSTIN shows as enabled for e-invoicing can file the self-declaration on the e-invoice portal (Dashboard > e-Invoice Exemption Declaration), signed with DSC or EVC. Filing the declaration does not change the enablement status, but it records why no IRN is being generated.
What is the 30-day time limit for reporting e-invoices?
GSTN first applied a time limit to taxpayers with AATO of ₹100 crore or more from 1 November 2023. From 1 April 2025, the limit was extended to taxpayers with AATO of ₹10 crore or more.
| Point | Position |
|---|---|
| Who is affected | Taxpayers with AATO of ₹10 crore or more |
| Time allowed | 30 days from the date of the document |
| Documents | All documents for which an IRN is generated: invoices, credit notes and debit notes |
| Effect of delay | The IRP rejects the document; no IRN is generated |
| Example | An invoice dated 1 April 2025 had to be reported by 30 April 2025 |
Taxpayers with AATO above ₹5 crore but below ₹10 crore must still generate e-invoices; the 30-day block does not apply to them at present. Even so, delaying the IRN is unwise, because the IRN and QR code must be on the invoice before it is issued to the buyer.
Can an e-invoice be cancelled or amended?
An IRN can be cancelled only in full, and only within 24 hours of generation on the e-invoice system. Partial cancellation is not possible. After 24 hours, an error in value or tax is corrected by issuing a credit note or debit note, which is reported to the IRP in the normal way. Details reported to the IRP also flow into the supplier's GSTR-1, so cancellations and notes must match the books and the return. Our article on GST returns in 2026, IMS and the three-year bar explains how these figures carry into GSTR-1 and GSTR-3B.
Practical checklist for businesses
- Compute aggregate turnover PAN-wise for every year from 2017-18 and keep the working on file.
- Confirm whether the business falls in any exempt class; if so, file the exemption declaration.
- Make sure the billing or ERP system generates IRNs before invoices are sent to customers.
- If AATO is ₹10 crore or more, set an internal deadline well inside 30 days for reporting every invoice and note.
- Review cancelled IRNs and credit or debit notes each month while preparing GST returns.
The information in this article reflects the law as on the date of publication and is for general guidance only.
CA. Kunal Darwani