E-Invoice & Dynamic QR Code — Master Summary
All rules, thresholds, exemptions, penalties, latest advisory and more, packed in ONE place!
E-INVOICE AND DYNAMIC QR CODE UNDER GST – MASTER SUMMARY!!
1. Legal Provisions & Framework
Sec. 31 | Mandates issuance of tax invoice |
R.48(4) | Certain registered persons must generate invoice by uploading details on IRP to obtain IRN |
R48(5) | Invoice without IRN = not valid invoice |
2. Applicability Based on Turnover (AATO)
AATO Threshold | Effective Date | AATO Threshold | Effective Date |
> ₹500 Cr | 01-Oct-2020 | > ₹20 Cr | 01-Apr-2022 |
> ₹100 Cr | 01-Jan-2021 | > ₹10 Cr | 01-Oct-2022 |
> ₹50 Cr | 01-Apr-2021 | > ₹5 Cr | 01-Aug-2023 |
- Turnover threshold is to be checked for any financial year from FY 2017-18 onwards. ONCE APPLICABLE, ALWAYS APPLICABLE
- If turnover exceeds threshold in current year, e-invoicing becomes applicable from the next FY.
- However, A Taxpayer having TO below 5 crore can VOLUNTARILY Opt for Einvoice using: https://einvoice1.gst.gov.in/Home/Enablement
3. Exemptions for E-Invoicing
SEZ Units (not developers) | Banks, NBFCs, Financial Institutions, Insurers | Goods Transport Agencies |
Passenger transport services | Multiplex cinemas (film exhibition only) | Govt. Dept/Local Authorities |
“I/We hereby declare that though our aggregate turnover in any preceding financial year from 2017-18 onwards is more than the aggregate turnover notified under sub-rule (4) of rule 48, we are not required to prepare an invoice in terms of the provisions of the said sub-rule” – Declaration Required by exempted Dealers on Each Invoice |
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Exemption is to entity as a whole and is not restricted by the nature of supply/transaction – Circular 186/18/2022 |
4. Recent Advisory (w.e.f. 01-Apr-2025)
- 30-day time limit to report invoice on IRP for AATO > ₹10Cr [ Eg: Inv dt 01-Apr must be reported by 30-Apr]
- CAUTION: IRN generation on a later date is only a facilitation by NIC Portal. However, if goods are intercepted during transit, only a valid e-invoice (not normal invoice) is accepted as per Rule 48(5).
- Non-reporting = No IRN generation =Invoice not valid
5. Requirement of Dynamic QR Code on B2C Invoices – w.e.f. 1st Apr 2021(after multiple extensions)
- For Registered Person having AATO > 500 CR for any FY starting from 2017-18 onwards
- Not Applicable on Insurer, Banking Company or a Financial Institution, GTA, Passenger Transportation Service Provider, Cinema and Multiplex, OIDAR services providers,
- If the supplier digitally displays a Dynamic QR Code and the B2C invoice contains a payment reference (transaction ID, UPI reference, etc.) linked to it, the invoice shall be deemed to have a QR Code
5. Transaction Type wise E-invoice Applicability Status
Type of Supply | Document Issued | E- Invoice & QR Code Applicable?
[ QR Code having embedded IRN Generated from IRP] |
Dynamic QR Code Applicable? [Self-Generated] | |
Other Than Exports | B2B Taxable Supply | Tax Invoice / CN / DN | Yes, If Turnover Exceeds 5 Cr* | NA |
B2C Taxable Supply | Tax Invoice / CN / DN | NO | Yes, if TO Exceeds 500 Cr [W.e.f 01-04-21] | |
B2B Exempt Supply | Bill of Supply | NO | NO [Proviso to Rule 49 Yet to be Notified] | |
B2C Exempt Supply | Bill of Supply | NO | ||
Exports | Exports [Including Exempted & B2C (as always) Supply] | Tax Invoice / CN / DN | Yes, If Turnover Exceeds 5 Cr | NA |
7. Different Ways to Generate E-invoice
- Use Bulk Generation Excel Utility > Create Json > Manually Upload on https://einvoice1.gst.gov.in/
- Use Excel Based Gepp Tool which stores your Recipient and HSN Data & Generate IRN
- Fill Data Directly Online on “Gepp-On website” (without creating and uploading Json) on https://einv-apisandbox.nic.in/gepp/#/
- Use Accouting software with Direct API Integration (Such As TallyPrime, Zoho, SAP, Miracle etc)
- GePP-On download link for Android/iOS mobile: https://gepp.einvoice1.gst.gov.in/downloads/MobileAppDownloads.html
- E-invoice verifier App: https://play.google.com/store/apps/details?id=com.chrgraj.eInvoice_verifier
8. Cancellation & Amendments
- CANCELLATION:
- IRN can be cancelled within 24 hours (from the time of generation of IRN)
- However, if the e-way bill is active & verified by officer during transit, cancellation of IRN not permitted.
- Once Cancelled, the same Invoice Number can not be used again to generate IRN
- AMENDMENTS:
- Amendments are not possible on IRP.
- Any changes in the invoice details reported to IRP can be carried out on GST portal (while filing GSTR-1) CAUTION: In such amendment, there will be diff. between E-Invoice data vs GSTR-1 data.
9. Penal Provisions
- Penalty for Non-Generation of E-waybill 20000 Or Tax Evaded Whichever is Higher [Sec 122(1)(i)].
- General penalty of up to ₹25,000 u/s 125 may be applicable for Non Compliance of B2C Dynamic QR Code.
10. Other Essential Aspects
- IRN PDF Storage: Portal allows download of IRN PDF only for 3 days. Store & back up immediately after generation.
- If supplier is liable to generate an e-invoice but fails to do so, the Input Tax Credit (ITC) claimed by the recipient will be under question!!
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