E-Invoicing – Whether The Relevant Provisions Of GST Law Require Patchwork?

Introduction

Effective from August 1, 2023, taxpayers with an annual turnover of more than INR 5 Cr will be recognized as "class of registered person" who will be mandated to generate e-invoice¹. Initially, the requirement to generate e-invoice was effectuated in October 2020 by making it mandatory for persons with annual turnover of more than INR 500 Cr and gradually, in a phased manner, the said limit was reduced to INR 10 Cr. The further trimming of threshold limit that too INR 5 Cr will undoubtedly cover substantial number of smaller taxpayers in the e-invoicing net.

It must be pointed out that e-invoicing ought not to be confused with the issuance of electronic invoices. E-invoice essentially means generation of a unique Invoice Reference Number ('IRN') by uploading certain key particulars of a GST invoice (created through taxpayer's own billing system) in a standard format on the e-invoicing portal.