E-invoicing: who must do it
Rule 48(4) of the CGST Rules requires an Invoice Reference Number (IRN) from the Invoice Registration Portal for B2B invoices, exports, supplies to SEZ, and credit and debit notes. This applies once aggregate turnover crosses ₹5 crore in any financial year from 2017-18 (Notification 10/2023-CT, from 1 August 2023). Turnover is taken at PAN level, across all GSTINs. Once you cross the threshold, the obligation stays even if turnover falls later. Notification 13/2020-CT, as amended, excludes these whatever their turnover: SEZ units (not developers); insurers, banks, financial institutions and NBFCs; goods transport agencies; passenger transport services; cinema admission in multiplex screens; and government departments and local authorities. An invoice that needed an IRN but has none is not a valid invoice (Rule 48(5)).
The 30-day reporting limit
GSTN's advisory of 5 November 2024 extended the 30-day limit to taxpayers with AATO of ₹10 crore or more, from 1 April 2025. It had applied to ₹100 crore and above since 1 November 2023. The IRP will not accept a document more than 30 days old, counting the document date as day one: an invoice dated 1 April must be reported by 30 April. It covers invoices and credit notes; whether debit notes are also blocked verify on the IRP before relying on a late debit note. Source: summary of the GSTN advisory.
E-way bill: value, Part B and validity
Rule 138 requires an e-way bill before moving goods whose consignment value, including tax, exceeds ₹50,000. States set their own limits for movement within the State; Maharashtra, Delhi and Tamil Nadu use ₹1 lakh verify. Inter-state movement to a job worker, and of handicraft goods by unregistered artisans, needs one at any value. Part B (vehicle details) may be left blank when goods go up to 50 km within the State to a transporter's premises. Validity is one day for up to 200 km plus one day for every further 200 km or part of it. For over-dimensional cargo it is 20 km a day. A day ends at midnight of the day after generation. You can extend validity within 8 hours either side of expiry.
GSTN's advisory of 18 December 2024 brought in three portal rules from 1 January 2025. E-way bills can be generated only for documents up to 180 days old. Extensions are capped at 360 days from generation. Multi-factor login was phased in and has been mandatory for all users since 1 April 2025. Source: GSTN advisory text.
Common questions
My turnover this year is ₹4 crore but it was ₹6 crore in 2021-22. Do I need e-invoicing?
Yes. The test is whether aggregate turnover exceeded ₹5 crore in any financial year from 2017-18. Once it has, e-invoicing applies from the notified date and does not switch off when turnover falls.
Do I need an e-invoice for a B2C sale?
No. E-invoicing covers B2B supplies, exports, supplies to SEZ and B2B credit and debit notes. Only businesses with AATO above ₹500 crore must print a dynamic QR code on B2C invoices.
Is the e-way bill limit on invoice value or consignment value?
Consignment value. That is the value on the invoice, bill of supply or challan, including GST and cess, but excluding exempt goods on the same document. Several invoices in one vehicle each need their own e-way bill if each crosses the limit.
What happens if goods are moved without an e-way bill?
Goods and the vehicle can be detained under s.129. Release requires a penalty of 200% of the tax payable (for an owner who comes forward), so compliance is far cheaper.