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Article Dated 16th July, 2025

E-Invoicing Under GST: Applicability, Process and Common Errors

What is E-invoicing?

As per Rule 48(4) of CGST Rules, notified class of registered persons have to prepare invoice by uploading specified particulars of invoice (in FORM GST INV-01) on Invoice Registration Portal (IRP) and obtain an Invoice Reference Number (IRN).

After following above ‘e-invoicing’ process, the invoice copy containing inter alia, the IRN (with QR Code) issued by the notified supplier to buyer is commonly referred to as ‘e-invoice’ in GST.

Because of the standard e-invoice schema (INV-01), ‘e-invoicing’ facilitates exchange of the invoice document (structured invoice data) between a supplier and a buyer in an integrated electronic format.

Please note that ‘e-invoice’ in ‘e-invoicing’ doesn’t mean generation of invoice by a Government portal.

Applicability of E-Invoicing

The applicability of e-invoicing has been introduced in a phased manner based on aggregate turnover.

Registered persons whose aggregate turnover in any preceding financial year from 2017-18 onwards exceed following amounts are required to prepare e-invoice. Refer Notification No. No. 13/2020–Central Tax Dated: 21st March, 2020 amended from time to time.

Phase

Effective date

Aggregate turnover of preceding F.Y

Phase 1

w.e.f. 01.10.2020

500 crores and above

Phase 2

w.e.f. 01.01.2021

100 crores and above

Phase 3

w.e.f. 01.04.2021

50 crores and above

Phase 4

w.e.f. 01.04.2022

20 crores and above

Phase 5

w.e.f. 01.10.2022

10 crores and above

Phase 6

w.e.f. 01.08.2023

5 crores and above

Faqs on applicability

For which businesses, e-invoicing is mandatory?

Currently, Registered persons whose aggregate turnover (based on PAN) in any preceding financial year from 2017-18 onwards, is more than prescribed limit i.e. 5 crores (Notification No. 10/2023–Central Tax Dated: 10th May, 2023), e-invoicing is mandatory.

Accordingly, once a taxpayer’s aggregate turnover exceeds Rs. 5 crore in any financial year starting from FY 2017-18 onwards, e-invoicing becomes mandatory from the beginning of the next financial year.

What documents are presently covered under e-invoicing?

  1. Invoices

  2. Credit Notes

  3. Debit Notes,

when issued by notified class of taxpayers (to registered persons (B2B) or for the purpose of Exports) are currently covered under e-invoice. Though different documents are covered, for ease of reference and understanding, the system is referred as ‘e-invoicing’.

What supplies are presently covered under e-invoice?

Supplies to registered persons (B2B), Supplies to SEZs (with/without payment), Exports (with/without payment), Deemed Exports, by notified class of taxpayers are currently covered under e-invoicing.

B2C (Business to Consumer) supplies can also be reported by notified persons?

No. Reporting B2C invoices by notified persons is not applicable/allowed currently.

Is e-invoicing applicable for NIL-rated or wholly-exempt supplies?

No. In those cases, a bill of supply is issued and not a tax invoice.

Whether the financial/commercial credit notes also need to be reported to IRP?

No, only the credit and debit notes issued under Section 34 of CGST/SGST Act have to be reported.

Whether e-invoicing is applicable for supplies by notified persons to Government Departments?

E-invoicing by notified persons is mandated for supply of goods or services or both to a registered person.

Thus, where the Government Department doesn’t have any registration under GST (i.e. not a ‘registered person’), e-invoicing doesn’t arise.

However, where the Govt. department is having a GSTIN (as entity supplying goods/services/ deducting TDS), the same has to be mentioned as recipient GSTIN in the e-invoice.

For which entities/sectors, e-invoicing is not applicable / exempt?

  1. Special Economic Zone Units

  2. Insurers

  3. Banking companies or financial institutions, including a non-banking financial company (NBFC)

  4. Goods Transport Agency (GTA) supplying services in relation to transportation of goods by road in a goods carriage

  5. Suppliers of passenger transportation service

  6. Suppliers of services by way of admission to exhibition of cinematograph films in multiplex screens

  7. g. Persons registered in terms of Rule 14 of CGST Rules (OIDAR)

Do SEZ Developers need to issue e-invoices?

Yes, if they have the specified turnover and fulfilling other conditions of the notification. In terms of Notification (Central Tax) 61/2020 dt. 30-7-2020, only SEZ Units are exempted from issuing e-invoices.

Is e-invoicing applicable to invoices issued by Input Service Distributor (ISD)?

No

Whether e-invoicing is applicable for supplies involving Reverse Charge?

If the invoice issued by notified person is in respect of supplies made by him but attracting reverse charge under Section 9(3), e-invoicing is applicable.

Process of generating E-invoice

  • Invoice Generation:

The taxpayer generates the invoice using their own ERP/accounting software in the prescribed schema (JSON format).

  • Upload to IRP:

The invoice data is uploaded to the Invoice Registration Portal (e.g., https://einvoice1.gst.gov.in).

  • IRN Generation:

The IRP validates the data, generates a unique IRN, and digitally signs the invoice.

  • QR Code & Acknowledgment:

A QR code is embedded in the invoice, and a signed copy is returned to the taxpayer.

  • GST Portal Auto-Population:

The data is shared with the GST and e-way bill systems for auto-population in GSTR-1 and e-way bill generation.

Faqs on process of generating E-invoice

What is an Invoice Registration Portal (IRP)?

Invoice Registration Portal (IRP) is the website for uploading/reporting of 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 the signature (DSC) of supplier mandatory while reporting e-invoice to IRP?

No

What I need to do to  generate an e-invoice?

A system/utility to report e-invoice details in JSON format to IRP and to receive signed e-invoice in JSON format from the Portal.

Whether any tool is provided to report invoices to IRP?

Yes. For entities not having their own ERP/Software solutions, they can use the free offline utility (‘bulk generation tool’) downloadable from the e-invoice portal.

Through this, invoice data can be easily reported to IRP and obtain IRN/signed e-invoice

What are various modes for generation of e-invoice?

Multiple modes are available so that taxpayer can use the best mode to generate IRN: 

a. API-based 

b. Offline Utility (freely downloadable from IRP)

Will IRP store/archive e-invoices?

No. IRP will only be a pass-through portal which performs prescribed validations on invoice data and generates IRN. It will not store or archive e-invoice data.

In case of breakdown of internet connectivity in certain areas, will there be any relaxation in the requirement to obtain IRN?

A localised mechanism to provide relaxation in such contingent situations is prescribed as per proviso to Rule 48(4) of CGST Rules. It reads as: “…Commissioner may, on the recommendations of the Council, by notification, exempt a person or a class of registered persons from issuance of invoice under this sub-rule for a specified period, subject to such conditions and restrictions as may be specified in the said notification.”

What is the file format in which invoice has to be reported to IRP?

Invoice details in prescribed schema (INV-01) have to be reported to IRP in JSON format. ‘JSON’ stands for JavaScript Object Notation.

It can be thought of as a common language for systems/machines to communicate between each other and exchange data.

As the ERP or Accounting software will generate it, taxpayer need not worry about it. This format is also used in GST system for reporting all data to GST System.

What is e-invoice schema?

‘Schema’ simply means a structured template or format. ‘e-invoice’ schema is the standard format for electronic invoice. It is notified as ‘Form GST INV-1’.

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

No. Invoice no. (e.g. ABC/1/2025-26) is assigned by supplier and is internal to business. Its format can differ from business to business and also governed by relevant GST rules.

How a typical IRN looks like?

Yes. The cancellation request can be triggered through ‘Cancel API’ within 24 hours from the time of reporting invoice to IRP.

However, if the connected e-way bill is active or verified by officer during transit, cancellation of IRN will not be permitted.

In case of cancellation of IRN, GSTR-1 will also be updated with such ‘cancelled’ status.

After generation of IRN, is there any time limit for generation of e-way bill (where applicable/desired)?

No such time limit is kept presently in the system.

Common Errors in E-Invoicing

Despite its advantages, taxpayers frequently encounter issues while implementing e-invoicing. Here are some common errors and how to avoid them:

1. Duplicate IRN Requests

Reason for error: Attempting to register a document again which is already registered and IRN is generated.

Resolution: Don`t fire the same request simultaneously. This results in one request giving the error as `Duplicate IRN request`. Best way to avoid firing of IRN request repeatedly for the same request, is update in your system with IRN number when the response comes back. Next time check the IRN, if it is not there, then fire for IRN.

2. Invalid HSN code(s)

Reason for error: Using outdated or incorrect HSN/SAC codes.

Resolution: Pl check the HSN code being passed and Cross-check the correctness of HSN code on e-invoice portal. Still, if you feel it is correct, then please send the details to the helpdesk for verification at e-invoice system side.

3. Invalid GSTIN

Reason for error: Typing errors or using inactive GSTINs for buyers

Resolution: Validate GSTINs using the GST portal or APIs before invoice submission.

4. IRN Not Generated

Reason: Technical errors due to improper JSON or schema mismatch.

Resolution: Use tools provided by the NIC or your GSP (GST Suvidha Provider) to validate JSON schema.

5. Incorrect Invoice Number Format

Reason: Changing invoice number format mid-year can break continuity and cause IRN mismatches.

Resolution: Maintain consistent invoice numbering throughout the financial year.

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