E-invoicing: separate the turnover test from the reporting deadline
The e-invoicing scope and the 30-day reporting restriction have different turnover tests. Check covered supplies, exemptions and the date of each document.
Notification 10/2023 lowered the e-invoicing threshold to aggregate turnover exceeding ₹5 crore from 1 August 2023. The test refers to any preceding financial year from 2017–18 onwards. Applicability also depends on the class of registered person, transaction and exemptions; crossing a threshold does not mean every document is covered.
Separately, the reviewed IRP advisory applies a 30-day reporting restriction from 1 April 2025 to taxpayers with AATO of ₹10 crore or more. It covers document types requiring an IRN, including applicable invoices, credit notes and debit notes. Check the date of the document being reported; do not use the original invoice date as the reporting date of a newly issued credit note.
An overseas supplier’s commercial invoice and a customs Bill of Entry are not domestic e-invoices generated by the Indian importer merely because goods are imported. Keep import-IGST reconciliation separate from the IRN requirements for your own covered supplies. Have your GST adviser confirm the turnover test, exemptions and current portal rules, and give each reporting task an owner and due date.
Questions we are getting
Are the e-invoicing threshold and the 30-day restriction identical?
No. They have different turnover tests and must be checked separately, together with transaction scope and exemptions.
Does a new credit note use the original invoice date for its reporting clock?
Do not assume that. Check the date of the document being reported and the current IRP validation rules with your GST adviser.
Primary reference
- GST Council: Notification 10/2023-Central Tax, 10 May 2023
- GST-authorised IRP advisory: 30-day reporting restriction effective 1 April 2025
Reviewed 2 October 2026. Historical references are labelled; confirm subsequent amendments before acting.