E-Invoicing-

Agenda
1. What is E-Invoicing?
2. Applicable to/ not applicable to
3. E-Invoice Process, Benefits & Challenges
4. How to Prepare
5. Circular no. 146/02/2021-GST
6. FAQs

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What is E-Invoicing

generation of invoice on an electronic portal run by the

Government.

E-invoicing
Or

a
B2B invoices issued by suppliers are uploaded on an e-
Electronic portal notified by the Government and authenticated
invoicing electronically

These invoices are further used in various compliances such as

preparation of GST returns, e-way bills etc. on the GST system

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Rule 48. Manner of issuing invoice.-
Inserted by CGST (Eighth Amendment) Rules, 2019 dated 13.12.2019
(4) The invoice shall be prepared by such class of registered persons as may be notified by the
Government, on the recommendations of the Council, by including such particulars contained
in FORM GST INV-01 after obtaining an Invoice Reference Number by uploading information
contained therein on the Common Goods and Services Tax Electronic Portal in such manner and
subject to such conditions and restrictions as may be specified in the notification.
[Provided that the 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.]
(5) Every invoice issued by a person to whom sub-rule (4) applies in any manner other than the
manner specified in the said sub-rule shall not be treated as an invoice.

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 Exemption and Requirement of E Invoice [NN 13/2020–CT dt 21.03.20]
In exercise of the powers conferred by sub-rule (4) of rule 48, Government on in supersession of
the notification No.70/2019–Central Tax, dated the 13th December, 2019, except as respects things done
or omitted to be done before such supersession, hereby notifies registered person, other than 5[a
government department, a local authority,] 1[a Special Economic Zone unit and] those referred to in sub-
rules (2), (3), (4) and (4A) of rule 54 of the said rules, whose aggregate turnover in 3[any preceding financial
year from 2017-18 onwards] exceeds 2[Twenty crore rupees], as a class of registered person who shall
prepare invoice and other prescribed documents, in terms of sub-rule (4) of rule 48 of the said rules in
respect of supply of goods or services or both to a registered person 4[or for exports].
2. This notification shall come into force from the 1st October, 2020.

1. Inserted by NN 61/2020-CT dated 30.07.2020

Subs. by NN 61/2020-CT dated 30.07.2020 for "one hundred crore rupees" and further Subs. by Noti. No.88/2020-CT dated 10.11.2020 w.e.f.
2. 01.01.2021 for "five hundred crore rupees" and again further Subs. by Noti. No.05/2021-Central Tax dated 08.03.2021 w.e.f. 01-04-2021 for "one
hundred crore rupees" and again further Subs by NN 17/2022-Central Tax dated 01.08.2022 w.e.f. 01.10.2022 for "twenty crore rupees"
3. Subs. by Noti. No.70/2020-Central Tax dated 30.09.2020 for "a financial year"
4. Inserted by Noti. No.70/2020-Central Tax dated 30.09.2020
5. Inserted by Noti. No.23/2021-Central Tax dated 01.06.2021 w.e.f. 01.06.2021

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Exempted Sectors & Businesses from E Invoice

a government department, a local authority,

SEZ Units (SEZ Developer not exempted from E Invoice)

Insurance, Banking, FI [including NBFCs] Rule 54(2)

Goods Transport Agency – Rule 54(3)

Passenger Transport Services– Rule 54(4)

Multiplex Cinema – Rule 54(4A)

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E-Invoicing - Applicable Scenario

Deemed Supply
B2B Supply
(Distinct Person)

Supply to/by SEZ

Developer Export
Deemed Export Credit Note/ Debit Note

Supply to
Government/PSUs

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E-Invoicing - Not Applicable Scenarios

Delivery/Job Work
Bill of Supply Challan B2C

Import ISD Exempt Supply

RCM(eg. Recipient
Exempted by NN
paying legal fees)
13/2020

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E- Invoicing - Evolution

1.10.2020 E- Invoicing implemented for above INR 500 crore

[Phase I] entities

1.01.2021 Implemented for above INR 100 crore entities from

[Phase II] 1.01.2021

1.04.2021 To be implemented for above INR 50 crore entities from

[Phase III] 1.04.2021{Not. No.5/2021]

1.04.2022 To be implemented for above INR 20 crore entities from

[Phase IV] 1.04.2022

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 10 Common GST Portals for E Invoice
In exercise of the powers conferred by section 146 read with sub-rule(4) of rule 48 and section 20 hereby,
notifies the following as the Common GST Electronic Portal for the purpose of preparation of the invoice in
terms of sub-rule (4) of rule 48 of the aforesaid rules, namely:-
(i) www.einvoice1.gst.gov.in; (ii) www.einvoice2.gst.gov.in;
(iii)www.einvoice3.gst.gov.in; (iv) www.einvoice4.gst.gov.in;
(v) www.einvoice5.gst.gov.in; (vi) www.einvoice6.gst.gov.in;
(vii) www.einvoice7.gst.gov.in; (viii) www.einvoice8.gst.gov.in;
(ix) www.einvoice9.gst.gov.in; (x) www.einvoice10.gst.gov.in.
Explanation.-For the purposes of this notification, the above mentioned websites mean the websites
managed by the Goods and Services Tax Network, a company incorporated under the provisions of section
8 of the Companies Act, 2013 (18 of 2013).
2. This notification shall come into force with effect from the 1st day of January, 2020.

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Terms related to E-invoicing
Invoice Registration Portal (‘IRP’) - notified e-portal
Invoice Reference Number (‘IRN’) - Unique identification number generated by the portal against every
invoice
QR Code: The IRP will also generate a QR code containing the unique IRN (‘hash’) along with some
important parameters of invoice and digital signature so that it can be verified on the central portal as well
as by an Offline App. This will be helpful for tax officers checking the invoice on the roadside where
Internet may not be available all the time. The web user will get a printable form with all details including
QR code. The QR code will consist of the following e-invoice parameters:
a) GSTIN of supplier & Recipient
b) Invoice number as given by Supplier
c) Date of generation of invoice
d) Invoice value (taxable value and gross tax)
e) Number of line items
f) HSN Code of main item (the line item having highest taxable value)
g) Unique Invoice Reference Number (hash

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How does it work?

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 Cancellation
 If there is a mistake, incorrect or wrong entry in the already
generated IRN, then it cannot be edited or corrected. The IRN
once generated cannot be modified or deleted To Cancel the
E-Invoice
 Only option is cancellation of e-invoice and generation of a new
IRN with the new invoice.
If e-way bill E-way bill
 Once it is cancelled, the IRN cannot be generated on the same
not generated generated
invoice. The cancellation is required to be done within twenty-
four hours from the time of generation.
Cancel the
 There is a facility to the user to cancel the IRN, if active e-way Cancel the e-
Invoice
bill is not there. That is, the ewaybill is not generated or the e- (within 24 hrs)
way bill
way bill generated and later cancelled, then the user is allowed
to cancel the IRN.
Cancel the E-
Invoice

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 Dynamic QR Code for B2C Invoices
No.14/2020–Central Tax] Dated: 21st March, 2020 In exercise of the powers conferred by the sixth proviso to rule 46, the
Government, in supersession of the notification No.72/2019– Central Tax dated the 13th December, 2019, hereby notifies
that an invoice issued by a registered person, whose aggregate turnover in 1[any preceding financial year from 2017-18
onwards] exceeds five hundred crore rupees, other than those referred to in sub-rules (2), (3), (4) and (4A) of rule
54 of said rules, and registered person referred to in section 14 of IGST Act, to an unregistered person (B2C invoice), shall
have Dynamic Quick Response (QR) code

Provided that where such registered person makes a Dynamic Quick Response (QR) code available to the recipient through
a digital display, such B2C invoice issued by such registered person containing cross-reference of the payment using a
Dynamic Quick Response (QR) code, shall be deemed to be having Quick Response (QR) code.

This notification shall come into force from the 2[1st day of December], 2020.

Rule 46 – 6th Proviso

Provided also that the Government may, by notification, on the recommendations of the Council, and subject to such
conditions and restrictions as mentioned therein, specify that the tax invoice shall have Quick Response (QR) code.

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Waiver of Penalty for Non Compliance of NN 14/2020 (i.e. Dynamic QR Code for B2C)
No.89/2020–Central Tax dated: 29th November, 2020

In exercise of the powers conferred by section 128, the Government hereby waives the amount of penalty
payable by any registered person under section 125 of the said Act for non-compliance of the provisions
of NN 14/2020–Central Tax, dated the 21st March, 2020, between the period from the 1st day of December,
2020 to the 1[30th day of June], 2021, subject to the condition that the said person complies with the
provisions of the said notification from the 2[1st day of July], 2021.

1. Subs. by Noti. No.6/2021-CT dated 30.03.2021 for "31st day of March"

2. Subs. by Noti. No.6/2021-CT dated 30.03.2021 for "01st day of April"

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 CBIC Circular on Dynamic QR Code

Circular Subject
No.146 dated: 23rd February, 2021 Clarification in respect of applicability of Dynamic Quick Response
(QR) Code on B2C invoices and compliance of notification 14/2020-
Central Tax dated 21st March, 2020 - Reg.

No.156 dated: 21st June, 2021 Clarification in respect of applicability of Dynamic Quick Response
(QR) Code on B2C invoices and compliance of notification 14/2020-
Central Tax dated 21st March, 2020 - Reg.

No. 165 dated 17th November, 2021 Clarification in respect of applicability of Dynamic Quick Response
(QR) Code on B2C invoices and compliance of notification 14/2020-
Central Tax dated 21st March, 2020 - Reg.

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 Q&A on Dynamic QR Code - Circular no. 146/02/2021
Issue: To which invoice is Notification No 14/2020- Central Tax dated 21st March, 2020 applicable?
Clarification: This notification is applicable to a tax invoice issued to an unregistered person by a
registered person (B2C invoice) whose annual aggregate turnover exceeds 500 Cr rupees in any of the FY
from 2017-18 onwards. However, the said notification is not applicable to an invoice issued in following
cases:
i. Where the supplier of taxable service is:
a) an insurer or a banking company or a financial institution, including a non-banking financial
company;
b) a goods transport agency supplying services in relation to transportation of goods by road in a
goods carriage;
c) supplying passenger transportation service;
d) supplying services by way of admission to exhibition of cinematograph in films in multiplex screens
ii. OIDAR supplies made by any registered person, who has obtained registration under section 14 of the
IGST Act 2017, to an unregistered person.

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 Q&A on Dynamic QR Code - Circular no. 146/02/2021
Issue - Would this requirement be applicable on invoices issued for supplies made for Exports?

Supplies made for exports, though such supplies are made by a registered person to an unregistered person, however,
as e-invoices are required to be issued in respect of supplies for exports, in terms of Notification no. 13/2020-Central
Tax, dated 21st March, 2020 treating them as Business to Business (B2B) supplies,
Note: Notification no. 14/2020- Central Tax, dated 21st March, 2020 will not be applicable to them.

Issue: What parameters/ details are required to be captured in the Quick Response (QR) Code?

Clarification: Dynamic QR Code, in terms of Notification No. 14/2020-Central Tax, dated 21st
March, 2020 is required, inter-alia, to contain the following information: -
i. Supplier GSTIN number
ii. Supplier UPI ID
iii. Payee’s Bank A/C number and IFSC
iv. Invoice number & invoice date,
v. Total Invoice Value and
vi. GST amount along with breakup i.e. CGST, SGST, IGST, CESS, etc.
Further, Dynamic QR Code should be such that it can be scanned to make a digital payment.

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Q&A on Dynamic QR Code - Circular no. 146/02/2021
Issue: If a supplier provides/ displays Dynamic QR Code, but the customer opts to make payment without
using Dynamic QR Code, then will the cross reference of such payment, made without use of Dynamic QR
Code, on the invoice, be considered as compliance of Dynamic QR Code on the invoice?

Clarification: If the supplier has issued invoice having Dynamic QR Code for payment, the said invoice
shall be deemed to have complied with Dynamic QR Code requirements. In cases where the supplier, has
digitally displayed the Dynamic QR Code and the customer pays for the invoice: -
i. Using any mode like UPI, credit/ debit card or online banking or cash or combination of various
modes of payment, with or without using Dynamic QR Code, and the supplier provides a cross
reference of the payment (transaction id along with date, time and amount of payment, mode of
payment like UPI, Credit card, Debit card, online banking etc.) on the invoice ; or

ii. In cash, without using Dynamic QR Code and the supplier provides a cross reference of the amount
paid in cash , along with date of such payment on the invoice; The said invoice shall be deemed to
have complied with the requirement of having Dynamic QR Code.

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Q&A on Dynamic QR Code - Circular no. 146/02/2021
Issues - If the supplier makes available to customers an electronic mode of payment like UPI Collect, UPI
Intent or similar other modes of payment, through mobile applications or computer based applications,
where though Dynamic QR Code is not displayed, but the details of merchant as well as transaction are
displayed/ captured otherwise, how can the requirement of Dynamic QR Code as per this notification be
complied with?

Clarification - In such cases, if the cross reference of the payment made using such electronic modes of
payment is made on the invoice, the invoice shall be deemed to comply with the requirement of
Dynamic QR Code. However, if payment is made after generation / issuance of invoice, the supplier shall
provide Dynamic QR Code on the invoice.

Issue: Is generation/ printing of Dynamic QR Code on B2C invoices mandatory for prepaid invoices i.e.
where payment has been made before issuance of the invoice?

Clarification: If cross reference of the payment received either through electronic mode or through cash or
combination thereof is made on the invoice, then the invoice would be deemed to have complied with the
requirement of Dynamic QR Code. In cases other than pre-paid supply i.e. where payment is made after
generation / issuance of invoice, the supplier shall provide Dynamic QR Code on the invoice.

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Q&A on Dynamic QR Code - Circular no. 146/02/2021

Issue: Once the E-commerce operator (ECO) or the online application has complied with the Dynamic QR
Code requirements, will the suppliers using such e-commerce portal or application for supplies still be
required to comply with the requirement of Dynamic QR Code?

Clarification: The provisions of the notification shall apply to each supplier/registered person
separately, if such person is liable to issue invoices with Dynamic QR Code for B2C supplies as per
the said notification. In case, the supplier is making supply through the Ecommerce portal or
application, and the said supplier gives cross references of the payment received in respect of the
said supply on the invoice, then such invoices would be deemed to have complied with the
requirements of Dynamic QR Code. In cases other than pre-paid supply i.e. where payment is
made after generation / issuance of invoice, the supplier shall provide Dynamic QR Code on the
invoice.

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 Q&A on Dynamic QR Code - Circular no. 156

Issue: Whether Dynamic QR Code is to be provided on an invoice, issued to a person, who has
obtained a Unique Identity Number as per the provisions of Sub-Section 9 of Section 25 of CGST
Act 2017?

Clarification: Any person, who has obtained a Unique Identity Number (UIN) as per the provisions
of Sub-Section 9 of Section 25 of CGST Act 2017, is not a “registered person” as per the definition
of registered person provided in section 2(94) of the CGST Act 2017.

Therefore, any invoice, issued to such person having a UIN, shall be considered as invoice issued
for a B2C supply and shall be required to comply with the requirement of Dynamic QR Code.

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 Q&A on Dynamic QR Code - Circular no. 156
Issue: UPI ID is linked to the bank account of the payee/ person collecting money. Whether bank
account and IFSC details also need to be provided separately in the Dynamic QR Code along with
UPI ID?

Clarification: Given that UPI ID is linked to a specific bank account of the payee/ person collecting
money, separate details of bank account and IFSC may not be provided in the Dynamic QR Code

Issue: In cases where the payment is collected by some person other than the supplier (ECO or
any other person authorized by the supplier on his/ her behalf), whether in such cases, in place
of UPI ID of the supplier, the UPI ID of such person, who is authorized to collect the payment on
behalf of the supplier, may be provided?

Clarification : Yes. In such cases where the payment is collected by some person, authorized by the
supplier on his/ her behalf, the UPI ID of such person may be provided in the Dynamic QR Code, instead
of UPI ID of the supplier.

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 Q&A on Dynamic QR Code - Circular no. 156
Issue: In some instances of retail sales over the counter, the payment from the customer in received
on the payment counter by displaying dynamic QR code on digital display, whereas the invoice, along
with invoice number, is generated on the processing system being used by supplier/ merchant after
receiving the payment. In such cases, it may not be possible for the merchant/ supplier to provide
details of invoice number in the dynamic QR code displayed to the customer on payment counter.
However, each transaction i.e. receipt of payment from a customer is having a unique Order ID/ sales
reference number, which is linked with the invoice for the said transaction. Whether in such cases, the
order ID/ reference number of such transaction can be provided in the dynamic QR code displayed
digitally, instead of invoice number.

Clarification: In such cases, where the invoice number is not available at the time of digital display of
dynamic QR code in case of over the counter sales and the invoice number and invoices are generated
after receipt of payment, the unique order ID/ unique sales reference number, which is uniquely
linked to the invoice issued for the said transaction, may be provided in the Dynamic QR Code for
digital display, as long as the details of such unique order ID/ sales reference number linkage with the
invoice are available on the processing system of the merchant/ supplier and the cross reference of
such payment along with unique order ID/ sales reference number are also provided on the invoice.

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 Q&A on Dynamic QR Code - Circular no. 156
Issue: When part-payment has already been received by the merchant/ supplier, either in
advance or by adjustment (e.g. using a voucher, discount coupon etc), before the dynamic QR
Code is generated, what amount should be provided in the Dynamic QR Code for “invoice
value”?

Clarification The purpose of dynamic QR Code is to enable the recipient/ customer to scan and pay the
amount to be paid to the merchant/ supplier in respect of the said supply. When the part-payment for
any supply has already been received from the customer/ recipient, in form of either advance or
adjustment through voucher/ discount coupon etc., then the dynamic QR code may provide only the
remaining amount payable by the customer/ recipient against “invoice value”. The details of total invoice
value, along with details/ cross reference of the part-payment/ advance/ adjustment done, and the
remaining amount to be paid, should be provided on the invoice.

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 Q&A on Dynamic QR Code - Circular no. 156
Issue: In cases, where receiver of services is located outside India, and payment is being
received by the supplier of services in foreign exchange, through RBI approved modes of
payment, but as per provisions of the IGST Act 2017, the place of supply of such services is in
India, then such supply of services is not considered as export of services as per the IGST Act
2017; whether in such cases, the Dynamic QR Code is required on the invoice issued, for such
supply of services, to such recipient located outside India?

Clarification No. Wherever an invoice is issued to a recipient located outside India, for supply of services,
for which the place of supply is in India, as per the provisions of IGST Act 2017, and the payment is
received by the supplier in foreign currency, through RBI approved mediums, such invoice may be
issued without having a Dynamic QR Code, as such dynamic QR code cannot be used by the recipient
located outside India for making payment to the supplier.

Also refer Circular No. 165/21/2021-GST dated 17th November, 2021

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B2B e-invoice QR Code vs. B2C Dynamic QR Code: Know the Differences
IRP-generated QR Code on B2B & Export Invoices, Credit & Debit Notes:

As per Rule 48(4) of CGST Rules (inserted vide Notification No. 68/2019 – Central Tax Dated 13-12-2019 and read with other
notifications), notified registered persons, in case of B2B & Export supplies, have to prepare invoice by uploading specified particulars in
FORM GST INV-01 on Invoice Registration Portal (IRP) and upon obtaining Invoice Reference Number (IRN). The Portal will also return a QR
Code which contains key particulars of the invoice including IRN.

The 64-character IRN need not be printed on the invoice, the QR code generated by IRP shall be printed on the invoice issued to the
buyer. (It was also clarified that printing of QR code on separate paper is not allowed. While the printed QR code shall be clear enough to
be readable by a QR Code reader, the size and its placing on invoice is upto the preference of the businesses.)
Self-generated Dynamic QR Code on B2C invoices

Notification No. 14/2020-Central Tax dated 21st March, 2020 which mandates entities with aggregate turnover > Rs. 500 crores in a FY to
include QR code on their B2C invoices. It was also specified that a Dynamic Quick Response (QR) code made available to buyer through
digital display (with payment cross-reference) shall be deemed to be having QR code. In this case, the QR Code is generated by supplier
himself.

The purpose of this Notification is to enable and encourage digital payments where buyer can scan the dynamic QR code and make
payment from mobile wallet directly. Today, many shops have static QR code at the payment counter which is scanned by the buyer but
the buyer has to enter the amount to be paid to the shop (in the mobile payment App).

The dynamic QR code, on the other hand, will have the payment details and thus ‘scan and pay’ in one go will be possible.

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FAQ’s
Will the e-Invoice format be the same for all categories of taxpayers?

All businesses need to issue e-invoices using the same e-invoice schema laid down by the GSTN. The
schema has mandatory and non-mandatory fields. All taxpayers are required to fill mandatory fields.
Specific businesses can use non-mandatory fields as per their requirement.

What is the maximum number of line items supported by an e-Invoice?

The maximum number of line items allowed per e-Invoice is 100.

Does an e-Invoice need to be signed again by the supplier?

The provisions of Rule 46 of the Central Goods and Services (CGST) Rules, 2017 apply here.
According to Rule 46, the signature/digital signature of the supplier or his authorised
representative is required while issuing invoices. However, a proviso to Rule 46 states that the
signature/digital signature shall not be required in the case of issuance of an electronic invoice
that is in accordance with the provisions of the Information Technology Act, 2000. Hence, it has
been interpreted that in the case of e-invoices, a supplier will not be required to sign/digitally
sign the document.

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FAQ’s
How can one verify the authenticity of an e-invoice?
Anyone can verify the correctness of an e-invoice by uploading the signed JSON into the e-invoice system,
by selecting the option ‘Verify Signed Invoice’ under the ‘Search’ option. One can also download the QR
Code Verify app and verify the QR code printed on the invoice.
Can more than one IRN be generated for the same invoice?
No, the e-invoice system checks in the Central Registry of the GST system to ensure that the same
invoice from the same supplier belonging to the same financial year is not being uploaded again for
generating more than one IRN. The IRP will reject such invoices.

Can a cancelled e-invoice number be used again?

No, once an IRN is cancelled, the same invoice number cannot be used again to generate another invoice.
If used again, the IRP will reject the same.

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FAQ’s
Will the bulk-uploading of invoices be possible?
Yes, details of invoices can be entered in bulk in an excel based bulk convertor tool, available on the e-
invoice portal. Thereafter, the JSON file must be generated and uploaded on the e-invoice portal after
logging into it. The IRN and QR code shall be generated in the form of a response JSON file.

For how long will the data be available on the Government Portal?

On the IRP, the data will remain for only 24 hours. However, once an invoice has been registered and
validated, it will be uploaded into the relevant GST return where it will be available for the entire
financial year.

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.

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FAQ’s
Is Invoice number same as Invoice Reference Number (IRN)?
No. Invoice no. (e.g. ABC/1/2019-20) is assigned by supplier and is internal to business. Its format can
differ from business to business and also governed by relevant GST rules. IRN, on other hand, is a unique
reference number (hash) generated and returned by IRP, on successful registration of e-invoice.

Do I need to print IRN on the invoice?

No. It’s optional. IRN is anyway embedded in the QR Code which is one of the mandatory particulars on
invoice
Do I need to print QR Code on the invoice? If so, what shall be its size and location on the invoice
copy?
Yes. The QR code (containing, inter alia, the IRN) which comes as part of signed JSON from IRP,
shall be extracted and printed on the invoice. This is one of the mandatory particulars of invoice
under Rule 46 of CGST Rules.

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 FAQ’s
If e-invoice is applicable and issued, am I supposed to issue copies of invoice in triplicate/duplicate?

Where e-invoicing is applicable, there is no need of issuing invoice copies in triplicate/duplicate. This is
clearly specified in Rule 48(6).

Where e-invoicing is applicable, is carrying e -invoice print during transportation of goods mandatory?

No. As per Rule 138A(2) of CGST Rules, where e-invoicing is applicable, “the Quick Reference (QR) code
having an embedded Invoice Reference Number (IRN) in it, may be produced electronically, for verification
by the proper officer, in lieu of the physical copy of such tax invoice.”

How will the supplier send the e-invoice to the receiver?

A suggested mechanism may be to exchange the PDF of the JSON received from IRP, (including QR code)
as the best authenticated version of the e-invoice for business transactions. However, a mechanism to
enable system-to-system exchange of e-invoices through ecosystem partners will be made available in due
course.

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FAQ’s

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.
For example, a taxpayer (say, a Firm of Advocates having aggregate turnover in a FY is more than Rs. 500 Cr.) is supplying
services to a company (who will be discharging tax liability as recipient under RCM), such invoices have to be reported by
the notified person to IRP.

There is an SEZ unit and a regular DTA unit under same legal entity (i.e., having same PAN).The aggregate
total turnover of the legal entity is more than Rs. 500 Crores( considering both the GSTINS) .However, the
turnover of DTA unit is below Rs.100crores for F.Y. 19-20. In the scenario, as SEZ unit is exempt from e-
invoicing, whether e-invoicing will be applicable to DTA unit?

Yes,because the aggregate turnover of the legal entity in this case is>Rs. 500 Crores.The eligibility is based on aggregate
annual turnover on the common PAN

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FAQ’s
Whether Turnover will be counted from 1.4.17 or 1.7.17?

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FAQ’s
Q - There is an SEZ unit and a regular DTA unit under same legal entity (i.e. having same PAN). In
one of the financial years since 2017-18, the aggregate total turnover of the legal entity is more
than notified limit (considering both the GSTINs), however, the turnover of DTA unit is below
notified limit. In this scenario, as SEZ unit is exempt from e -invoicing, whether e-invoicing will
be applicable to DTA Unit?

Ans - Yes, it will be applicable, because the aggregate turnover of the legal entity in this case
exceeds the notified limit. The requirement is based on ‘aggregate turnover’ on the common
PAN.

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FAQ’s
We need to show abated value in the invoice? How to report in such scenarios?

Some supplies are eligible for abatement on value.

For example, in real estate, where the taxable value is 67% of the agreement value. T

o report invoices in such scenarios, below workaround is suggested:

Pre_Tax_Value = Rs. 1,00,00,000
Taxable_Value = Rs. 67,00,000
GST Amount = Rs. 5,00,000
Other Charges (item level) = Rs. 33,00,000 (Abatement Charges)
Total_Inv_Value = Rs. 1,05,00,000

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