What is E-Invoicing under GST, w.e.f. 01-04-2022

What is E-Invoicing under GST, w.e.f. 01-04-2022


An e-invoice is a Tax Invoice that is normally issued by every registered taxpayer but it contains some additional information in the form of a QR Cod

What is e-Invoicing?

An e-invoice is a Tax Invoice that is normally issued by every registered taxpayer but it contains some additional information in the form of a QR Code. The tax invoice generated through accounting software i.e. Tally, Busy etc. are transmitted on the IRP i.e. on Invoice Registration Portal or say e-invoicing portal in JSON file. The government portal validates the information and returns back the JSON file with a digital signature after generating IRN (unique invoice reference number for each invoice) and adding a QR Code. The said JSON file is imported into the Accounting/ ERP system that enables invoices to be printed with QR Code.

‘e-invoice’ in ‘e-invoicing’ does not mean the generation of invoice by Government Portal. Government Portal just receive the JSON file of the invoice generated by the supplier and it validates the data, generates IRN and adds a QR Code and returns back the signed JSON to the supplier.

Process of e-invoicing

Supplier Invoice Registration Portal GST System Buyer
  • Seller will prepare Tax Invoice with its accounting software
  • Upload JSON file on the IRP system
  • Validates Invoice data
  • Generates IRN
  • Sends Invoice payloads to GST System
  • Sends details to e-way bill system
  • Rules out the existence of the same IRN in the GST System
  • Auto-Populate Invoice details in GSTR-1/2A Auto populate
  • Buyer can view the Invoice details in GSTR-2A
  • With QR Code on Invoice Copy, he can check the authenticity of the e-invoice  by
    uploading the JSON sent by the supplier
  • Receive the signed JSON with IRN & e-way bill whenever required
  • Issue Invoice to Buyer with IRN & QR Code
  • GSTR-1 gets auto-updated with invoice details
  • Sign the Invoice
  • Adds QR code to JSON
  • send back signed JSON to the supplier
Relevant Provisions/ References
  • Section 31 of the GST Act – provides for the issue of invoices in the prescribed format
  • Rule 46 (r) – provides for mentioning of QR Code where the invoice is issued u/r 48(4)
  • Rule 48(4) – provides that such class of registered persons as may be notified shall issue an e-invoice
  • Rule 48(5) – provides that if an e-invoice is not issued even if it is required to be issued, then the invoice so issued shall not be valid.
  • FAQ’s
  • E-Invoice Schema Not. No. 60/2020 dated 30.07.20 CT
  • Notifications
Sno. Notification No. Aggregate Annual Turnover exceeds  in any FY since 17-18 Effective Date
1 61/2020 dated 30.07.20 ct 500 Crores 01/10/2020
2 88/2020 dated 10.11.20 ct 100 Crores 01/01/2021
3 05/2021 dated 08/03/21 ct 50 Crores 01/04/2021
4 01/2022 dated 24/02/22 ct 20 Crores 01/04/2022

Who is liable to issue an e-Invoice

Every registered taxable person whose aggregate annual turnover exceeds Rs. 20 Cr in any of the financial years since 2017-18 is liable to issue e-invoice by way of uploading its tax invoice in JSON file on Invoice Registration Portal (IRP) following e-invoice schema in INV-01 and getting back digitally signed JSON from IRP with IRN and QR Code.
  • A registered person whose aggregate annual turnover in any preceding financial year from 2017-18 onwards exceeds Rs. 20 Cr are liable for e-Invoicing.
  • E-Invoicing applies to the supply of goods or services or both.
  • E-Invoicing applies to export (with or without payment) also. (Not. No. 70/2020 CT dated 30.09.20)
  • Applies to B2b transactions only.
  • Applies supplies to SEZ Unit
  • Applies to Deemed Export

Documents covered under e-Invoicing

  • Tax Invoice
  • Debit Note
  • Credit Note

Exemption from e-Invoice

Entity Level Exemption –

  • As per Notification No. 13/2020, CT dated 21.03.2020 registered persons covered by sub-rule (2), (3), (4) & (4A) of Rule 54 are exempt from issuing e-invoices, such as –
    • Insurance, Banking or Financial Institution including NBFC [Rule 54(2)]
    • Goods Transport Agency transporting goods by road [Rule 54(3)]
    • Supplier of passenger transportation service [Rule 54(3)]
    • Person supplying services by admission to an exhibition of cinematographic film on the multiplex screen
    • SEZ Unit as per Notification No. 61/2020 CT dated 30/07/20 exempted.

Document Level Exemption-

  • Bill of Supply
  • Self Invoice in case of RCM u/s 9(4)
  • Advance Payment
  • Delivery Challan
  • Financial Debt/ Credit Note

Transaction Level Exemption-

  • B2c transactions
  • Non-GST Supplies (alcoholic liquor, Petrol, Diesel etc)
  • Bill of Entry in case of Import
  • Nil rated or exempted supplies

Objectives and advantages of e-invoicing

  • e-Invoicing ensures real-time reporting of invoices on the Government Portal and therefore it reduces the chances of manipulation to avoid the tax.
  • Secondly, it shall facilitate auto reporting of invoice details in GSTR-1 of the supplier and GSTR-2A of the recipient.
  • Facilitate auto-generation of e-way bills.
  • Standardize the invoice format which shall reduce the disputes among the transacting parties.
  • In this manner, it will improve overall business efficiency.

The disadvantage of not issuing e-invoices when required

  • An invoice issued in any manner other than in terms of rule 48(4) shall not be treated as a valid invoice.
  • Disentitle the recipient from claiming ITC.
  • It may also attract a penalty for not issuing a valid tax invoice u/s 122.

The time limit for reporting e-invoices on IRP

No there is no time window. It is real-time reporting.

Can the e-invoice be cancelled?

Yes, it can be cancelled within 24 hours of reporting to IRO through “Cancel API”. After cancellation, the GSTR-1 will be updated. However, if the connected e-way bill is active and verified by the authority during transit, then cancellation of the e-invoice will not be permitted by the IRP.

Amendment in e-invoicing

IRP does not allow amendment in e-invoices. However amendments, if any, needed can be done as usual on the e-filing portal while filing GSTR-1. However such changes will be flagged to the proper officer for information.

Will the e-invoice details be pushed to the GST System? Will they populate in the return?

Yes. On successful reporting of invoice details to IRP, the invoice data (payload) including
IRN will be saved in GST System. The GST system will auto-populate them into GSTR-1 of the supplier and GSTR-2A of respective receivers.
With the source marked as ‘e-invoice’, IRN and IRN date will also be shown in GSTR-1 and GSTR-2A.

Where e-invoicing is applicable, is carrying e-invoice print during transportation of goods mandatory?

No. As per Rule 138A(2) of CGST Rules, where e-invoicing is applicable, “the Quick Reference (QR) code having an embedded Invoice Reference Number (IRN) in it, maybe produced electronically, for verification by the proper officer, instead of the physical copy of such tax invoice.”

What data is embedded in QR Code?

The QR code will consist of the following key particulars of e-invoice:
a. GSTIN of Supplier
b. GSTIN of Recipient
c. Invoice number, as given by Supplier
d. Date of generation of invoice
e. Invoice value (taxable value and gross tax)
f. Number of line items
g. HSN Code of the main item (line item having highest taxable value)
h. Unique IRN (Invoice Reference Number/hash)
i. IRN Generation Date

How will the QR Code be received?

The QR code is part of signed JSON, returned by the IRP. It is a string (not an image), which the ERP/accounting/billing software shall read and convert into a QR Code image for placing on the invoice copy, like this.

What is a dynamic QR Code? Does it have any relevance for B2B e-invoicing?

  • Dynamic QR code applies to entities with aggregate turnover > Rs. 500 crores.
  • Applies to B2c invoices
  • It facilitates digital payment.
  • Dynamic QR Code enables the payer to make the payment through UPI in one go. It contains the bank details in an image format.
  • Dynamic QR CODE is generated by the taxable person himself with the help of a QR Code generating machine whereas the IRN in the case of e-invoice is generated by the IRP.
  • It does not have any relevance with B2B transactions as those transactions are covered by e-invoice.

What do businesses need to do, to be e-invoice ready?

Businesses will continue to issue invoices as they are doing now. Necessary changes on account of e-invoicing requirements (i.e. to enable reporting of invoices to IRP and obtain IRN), will be made by ERP/Accounting and Billing Software providers in their respective software. They need to get the updated version having this facility.

What is an Invoice Reporting Portal (IRP)

Invoice Registration Portal (IRP) is the website for uploading/reporting invoices by the notified persons. Vide notification no. 69/2019-Central Tax dated 13.12.2019, ten portals were notified for the purpose of preparation of the invoice in terms of Rule 48(4).

Is e-invoicing voluntary?

No, it is not optional. Presently, only the notified class of persons will be allowed/enabled to report invoices to IRP.

Will it be possible to bulk upload invoices to IRP?

Yes. It is possible. The offline utility (‘bulk generation tool’) serves this purpose. Further, the ERP or accounting systems used by large taxpayers can be designed in such a way that they can report invoices in bulk to IRP.

Is the Invoice number the same as Invoice Reference Number (IRN)?

No. Invoice no. (e.g. ABC/1/2019-20) is assigned by the supplier and is internal to the business. Its format can differ from business to business and is also governed by relevant GST rules. IRN, on other hand, is a unique reference number (hash) generated and returned by IRP, on successful registration of an e-invoice.

How a typical IRN looks like?

IRN  is a unique 64-character hash, e.g. 35054cc24d97033afc24f49ec4444dbab81f542c555f9d30359dc75794e06bbe.  It is not required to be printed on the invoice as it is already embedded in the QR Code printed on the Invoice.



Saral Tax India | सरल टैक्स इंडिया: What is E-Invoicing under GST, w.e.f. 01-04-2022
What is E-Invoicing under GST, w.e.f. 01-04-2022
An e-invoice is a Tax Invoice that is normally issued by every registered taxpayer but it contains some additional information in the form of a QR Cod
Saral Tax India | सरल टैक्स इंडिया
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