Who is Required to Generate E-Invoices Above the Threshold?

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Electronic invoicing adoption intends to plug revenue leakage risks and improve transparency ecosystems. However, pursuing lower eligibility thresholds also risks disrupting the possibility of ecosystem constituents attaining stability.

Let’s examine key aspects determining stakeholders mandated for compliance above set thresholds and reasonable transitional relaxations aiding assimilation.

Entities Required to Generate E-Invoices

Tax administrations remain obligated to uphold twin objectives around extensive formalization, intending fullproof documentation protocols integration for revenue visibility and risk mitigation objectives, while also pursuing inclusive assimilation policies minimizing disruption possibility for economic participants and managing transitional procedural enhancements.

Let’s examine key constituents warranting mandates for electronic invoicing compliance:

  1. Principal Business Categories

The eligibility provisions majorly encompass all varieties of registered taxpayers undertaking normal business transactions in the goods or services domain requiring integration. Thus, usual B2B supplies by regular dealers, B2C large invoice transactions by composition scheme affiliates where turnover exceeds threshold, small services enterprises engaged in intra-state trade, e-commerce model mandated suppliers, etc. 

Broadly attract mandates requiring them to report details of their B2B invoices and allied credit/debit notes amendatory transactions onto designated Invoice Registration Portal systems, enabling appropriate validation mechanisms, protecting revenue interests, and improving transparency.

  1. Special Category Registrations

Special trade schemes also warrant obligations when turnover margins are breached. For instance, large composition dealers required to make inter-state chargeable supplies or SEZ developers raising domestic invoices for DTA clearances are obligated to generate IRN as their liability positions come under revenue visibility requirements necessitating formal invoicing that integrates key aspects like item-wise breakup of consignments, applicable tax rates, destination party particulars, etc.

  1. Independent GSTINs

Importantly, independent entities registered under separate GSTINs, although operating under a common PAN umbrella, also attract compliance requirements as regulators focus on group-level aggregate turnover given the probability of inter-GSTIN stock transfers not getting documented appropriately, thereby undermining revenue reconciliation objectives. 

  1. Foreign Entities

Another key facet warrants foreign business enterprises importing goods into India for warehousing to directly undertake domestic outward supplies, thereby requiring local GST registration for settlement. 

They are also obligated to issue IRN in B2B transactions to enhance transparency around domestic transactions, allowing reconciling tax liabilities while claiming input tax credits on the basis of documents generated. However, exemptions cover secondary or ancillary overseas contractors not having a direct Indian GST presence.

  1. Past Turnover

The liability also encompasses retrospective consideration warranting taxpayers back mapping the highest turnover slab recorded in previous financial years starting from 2017–18 post GST implementation to squarely fit into relevant bracket applicability for mandatory integration if exceeding the respective year’s notified levels rather than only analyzing current fiscal turnover, thereby reducing the probability of subjective evaluation and ensuring extensive enterprise coverage with reasonable time allowances for change management.

Thus, barring reasonable exclusions, entities with commercial transactions in the goods or services domain warrant integration. Now let’s analyze the key documentation scope.

Mandatory E-Invoicing Above the Threshold

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While foundational record generation is imperative, relevant carve-outs addressing key revenue protection risks and initial assimilation challenges remain vital, providing an initial Vargas latitude covering stakeholders across sectors.

Now let’s examine the types of transactions and documents warranting obligations: 

  1. B2B Invoices

The compliance procedure encompasses reporting details of B2B invoices issued to other registered recipients covering normal taxable outward supply transactions undertaken to enhance transparency, allowing proper reconciliation of returns and taxes deposited between supplying entities and corresponding claiming parties while removing the probability of disproportionate credit claims or revenue leakage avenues based on inconsistencies in unstructured documentation-related gaps.

  1. Credit/Debit Notes

Given amendatory transactions like credit or debit notes carry a direct revenue impact by either lowering or enhancing the applicable GST burden, corresponding reporting mandates also cover them, requiring businesses to submit details onto the IRP for a corresponding validation reference number, allowing changes to reflect correctly in tax returns. Thereby plugging potential-duty leak sources.

  1. Export Invoices

An important category warranting integration encompasses export invoices issued to overseas purchasers that, although qualify for zero tax ratings as considered deemed supplies under IGST settlement cycles, require corresponding documentation to substantiate foreign currency repatriation, validate deemed ITC refund disbursals, and mitigate reassessment risks during audits. Hence, their coverage intends to remove camouflaged domestic diversions.

  1. SEZ Supplies

Another variety includes commercial invoices raised by developers operating Special Economic Zones supplying goods or services to registered buyers in the Domestic Tariff Area, which require corresponding GST discharge and warrant diligent integration to facilitate necessary counterparty ITC claim admissibility upon reconciling with corresponding liability flows reported appropriately in periodic returns. 

Therefore, we see key transaction characteristics determine documentation requirements from a value, supply class, and partner type standpoint rather than operational or industry classifications.

Also Read: What Is E-Invoicing? Is It Mandatory For Businesses Above Rs.5 Crore Turnover?

E-Invoice Requirements for Exceeding the Threshold

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Appropriate threshold application remains vital, balancing extensive onboarding objectives while also minimizing disruption risks. Therefore, three key considerations hold prominence in determining accurate applicability scenarios: turnover recorded, basis of calculations, and reasonable time allowances.

Turnover Consideration

The eligibility turnover benchmarks offer a vital starting point for assessing applicability scenarios for normal category transactions involving regular supply domains. The current threshold stands maintained at INR 10 crore aggregate turnover levels on pan-India operations, thereby reasonably covering the taxpayer base with well-structured documentation workflows, minimizing challenges for change management, along with the next lower threshold of beyond INR 5 crore turnover also notified for rollout in the next fiscal year, thereby denoting governments commitments towards continuing extensive coverage reflecting global harmonization practices.

Retrospective Applicability

Another key highlight warrants mandatory self-assessment by taxpayers, as well as factoring in the highest turnover thresholds recorded in any financial year post-GST implementation from the 2017–18 period instead of only current fiscal cycle numbers, thereby reducing sporadic or seasonal spikes linked to evaluation ambiguity targeting genuine large principal revenue contributing enterprise categories within the phased roadmap and minimizing rollout risks for authorities, as well as giving reasonable transition time for consultant-dependent enterprises further down supply chains.

PAN-Based Evaluation

Thus, the aggregate turnover determined warrants mandatory summation of figures reported entities having common PAN tagging but distinct goods and services identification numbers mapped with revenue authorities for registration and filing purposes, thereby taking holistic enterprises group-level visibility rather than sporadic numbers reported by state-wise entities individually, curtailing camouflaged revenue reconciliation avoidance risks by ensuring wholesome documentation compliance integration.

Therefore, the essence behind key considerations encompassing recorded history analysis, legal classifications, and reasonable time allowances is to facilitate accurate applicability determination and extensive onboarding adherence objectives.

If you want to know the role of e-way bill admins and subusers, then click on this blog link by Captainbiz.

Also Read: Latest GST And E-Invoicing Updates Simplified

Entities Obligated to Use E-Invoices

While discussing principal constituents earlier, another key responsibility facet warrants highlight covering sectors where customized documentation workflow complexities require a staged approach allowing reasonable transition time for corresponding digitization and integrations impacting service delivery before enforcing similar level mandates necessitating key outs.

  1. Registered Suppliers

For usual normal taxpayers encompassing all common business models spanning trade, logistics, or small services enterprises, the applicability scenarios discussed requiring extensive documentation compliance hold ground covering structured enterprise integration, minimizing large-scale disturbances, although factors like external dependencies, etc. require accommodation addressed separately.

  1. Special Registered Dealers

However, given the significant procedural handling uniqueness and reliance by a wider population in a few sectors, like passenger insurance or banking, that warrant tailored IT integrations, legislative backing through current exclusions intends to safeguard continuity risks, although larger participants within these special categories also expect coverage in the next phases after attaining sufficient capability improvements.

  1. SEZ Developers

Another key category forming a separate inclusion list encompasses players operating as developers in special economic territories raising invoices for domestic clearances, which come under the taxable supplies category, although certain additional exemptions and therefore warrant obligations ensure diligent integration.

  1. Distinct Persons

Additionally, often large principal manufacturers or traders function through a network of vertically demerged state-wise entities registered as distinct persons for operational ease, and although they may qualify for special valuations or assessments, corresponding documentation integration warrants the necessary basis for aggregate turnover positions and group-level consolidation following the interlinked nature of such units, allowing limited sporadic exclusions in specific scenarios only.

Therefore, based on reasonable revenue visibility objectives and considering crucial service delivery dependencies, e-invoicing obligations stand adequately customized, targeting extensive coverage across a sizeable enterprise pool participating actively in goods and services transactions while understanding crucial transitional aspects. 

Threshold for E-Invoice Generation

The Indian government has mandated a value-based threshold for the generation of e-invoices under the Goods and Services Tax (GST) regime. Currently, all registered/ an annual aggregate turnover above Rs. 20 crore must generate an electronic invoice (e-invoice) for B2B transactions.

This threshold has been fixed based on value to systematically phase in compliance across businesses. The larger your turnover, the earlier you need to adopt e-invoicing. The threshold is expected to be revised downward over time as the ecosystem expands.

In addition, e-invoicing applicability has been introduced in a selective, staggered manner across industries and sectors. For instance, companies in the banking, financial services, and insurance sectors were mandated in October 2020, while those in passenger transport, movies, restaurants, etc. came under the ambit by April 2021.

Such staggered timelines aim to assimilate feedback from initial cohorts, expand system capacity, and refine protocols before expanding to other sectors. Gradual onboarding allows for resolving unanticipated issues upfront.

Also Read: E-invoice Threshold in India: Everything You Need to Know

Applicability of E-Invoicing Above the Threshold

All registered businesses that have to file GST returns and have annual turnover above the Rs 20 crore threshold need to generate e-invoices for all B2B transactions. However, certain categories of registered persons continue to remain exempt from this requirement even if turnover exceeds the threshold.

Certain key aspects require consideration for determining accurate applicability scenarios:

  1. Value-Based Exemptions

Special economic zone (SEZ) units, insurers, or banking companies supplying services to account holders are excluded from the e-invoice generation requirement despite high turnover. The value-based turnover threshold is not applicable to such entities, and they continue to get exemptions.

  1. Industry-Specific Exemptions

Apart from value-based exemptions, certain industry-specific exemptions have also been notified. For instance, passenger transportation services through various modes (rail, road, and air) as well as movie exhibitors have been exempted from the e-invoicing requirement currently, irrespective of turnover.

  1. Procedural Dispensations

Additionally, certain procedural dispensations from the e-invoice generation mandate have been provided for export transactions, SEZ supplies, and certain notified classes of registered persons. This aims to ease the compliance burden for such categories.

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  1. Administrative Relaxations

Considering initial procedural challenges and ecosystem constraints, the government has also provided administrative relaxations. For instance, there is no penalty to be charged for procedural invoice errors in the first six months. Phase-wise linking of invoices with IRN also allowed for gradual onboarding. Thus, the calibrated approach intends to provide reasonable transitional relaxations, facilitating ecosystem preparedness and minimizing revenue threats.


Therefore, we see that e-invoicing roadmaps have consciously adopted graded thresholds for a wider set of taxpayers while also factoring in key dependency and preparedness constraints, seeking reasonable transition time for specialized sectors and procedures vital from a national transparency enhancement and trade continuity facilitation standpoint rather than seeking extensive rapid high disruption assimilation risks hindering inclusive formalization.

Frequently Asked Questions

  • Can distinct persons with separate GSTIN transfers also consider the possibility of an exemption if their individual turnover stays below threshold levels?

Since aggregate turnover warrants mandatory inclusion of values from B2B transactions between company distinct persons for evaluating thresholds, reasonable exemptions have been carved out for such internal movements, keeping obligated compliance requirements currently limited to external supply integration only.

  • Considering extensive procedural enhancements still underway across authorities, will taxpayers get more relaxation time for mandatory integration if current systems are unable to adapt so rapidly?

A balanced approach seems constructive to uphold digitization roadmaps without risking unwarranted rapid corrosion of enterprise productivity, which remains vital for export-led growth. Hence, collaborative mechanisms involving consultations across industry associations, tax consultants, etc. become vital to representing genuine ecosystem constraints and securing reasonable relaxations.

  • If group turnover exceeds the overall threshold, whereas for a particular distinct person, vertical turnover is negligible and lacks wherewithal currently, can exemptions apply, avoiding immediate mandates?

Vertical-wise carve-outs seem difficult since cumulative turnover encompasses all mapped entities uniformly. However, outsourcing assistance modes can help such units integrate necessary documentation compliance into their workflows, preventing punitive actions until sufficient capability improvements are attained, enabling respective procedural management.

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Ahana Das Freelancer
Ahana is an accomplished writer who has covered her graduation in English Honours. Having written in various subjects, she takes particular interest in writing content on personal finance, investing, budgeting and financial planning and her articles on finance and current affairs are seldom published in global newspapers.

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