Come August 1, an additional over 4 lakh assesses will be required to issue e-invoice mandatorily as the new threshold of aggregate annual turnover of ₹5 crore will be in place from said date.

At present. the threshold is ₹10 crore, which was ₹500 crore when mandatory generation of e-invoice implemented from October 1, 2020. At present, around 6 lakh assesses are required to comply with this mandatory norm, which will swell to around 10 lakh after lowering the threshold, says Dheeraj Rastogi, an Indian Revenue Service Officer of 1994 batch and Executive Vice President with GSTN. This number does not include exempted categories such as banks, Non-Banking Financial Companies or insurance companies.

As per Rule 48(4) of CGST Rules, notified class of registered persons have to prepare an invoice by uploading specified particulars of the invoice (in FORM GST INV-01) on Invoice Registration Portal (IRP) and obtain an Invoice Reference Number (IRN). After following the above ‘e-invoicing’ process, the invoice copy containing inter alia, the IRN (with QR Code) issued by the notified supplier to the buyer is commonly referred to as ‘e-invoice’ in GST.

Because of the standard scheme, ‘e-invoicing’ facilitates the exchange of the invoice document (structured invoice data) between a supplier and a buyer in an integrated electronic format. It is important to note that ‘e-invoice’ in ‘e-invoicing’ doesn’t mean the generation of an invoice by a government portal. The invoice not registered on the portal will not be valid. In such a situation, input tax credit (ITC) on the same cannot be availed by the recipient and will attract applicable penalties. 

“As on date, over 60 lakh invoices are generated on a daily basis which could increase to 65-67 lakhs per day on or After August 1,” Rastogi said. As more new entrants are businesses in medium businesses, efforts are there to provide hand-holding. He also informed that assesses will not have to pay anything to IRPs for basic services, but for value added services, some payment may be required.

Experts believe e-invoicing is good, but new entrants there could face some initial challenges. Shilpa Dhobale, Head (Product & Strategy), at IRIS Business Services, one of the first private e-invoice registration portals authorized by the government, says in an e-invoice, accuracy and getting it right the first time is of utmost importance for once e-invoice is generated it cannot be edited. There is a limited window for cancellation. Thus, “a meticulous approach is required to grasp the intricacies of the e-invoice standard, validation rules, and handling specific business scenarios while undertaking billing system upgrades and aligning processes as mandated,” she said.

According to Harpreet Singh, Partner, KPMG, while E-invoicing facilitates the free flow of credits, it becomes equally crucial for the recipients to ensure vendor compliance on this aspect in order to eliminate chances of input tax credit denial. This calls for implementing robust IT systems on both sides of the supply chain. “India is slowly but surely moving towards 100% e-invoicing, next steps would be the reduction of the threshold to Rs 1 Crores and then making it mandatory for all B2B transactions. Thus, all dealers in B2B businesses should be ready to embrace this technological advancement,” added Singh.

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