GST e-Invoicing Compliance & IRN

E-invoicing under GST is governed by Rule 48(4) of the Central Goods and Services Tax (CGST) Rules, 2017, read with Notification No. 78/2020-Central Tax dated 15 October 2020, which extended the e-invoicing mandate to notified classes of registered persons.

Mechanism: Rule 48(4) requires notified taxpayers to prepare invoices by uploading specified particulars in FORM GST INV-01 to the Invoice Registration Portal (IRP). The IRP validates the data, generates a unique Invoice Reference Number (IRN), digitally signs the invoice, and returns it to the supplier along with a QR code. An invoice issued by a notified person otherwise than in this manner is not treated as a valid tax invoice under the CGST Act and Rules — a defect that can jeopardise the recipient's ITC claim under Section 16.

Scope: E-invoicing applies to B2B supplies, exports, and credit/debit notes issued by taxpayers notified under successive Central Tax notifications amending the Rule 48(4) threshold. Supplies to unregistered persons (B2C) and specified categories separately notified (SEZ units, banks/NBFCs, GTAs, insurers, passenger transport services) remain outside the mandate.

Compliance consequence: Non-generation of an IRN for a notified supply attracts the general penalty under Section 122 of the CGST Act for issuing an invoice that does not comply with the Act/Rules, in addition to the invoice being treated as invalid for ITC purposes at the recipient's end.

This service covers IRP onboarding, IRN generation workflow, and e-invoicing compliance review under Rule 48(4)/Notification 78/2020-CT.

GST e-invoicing is the system under which every B2B invoice from a registered business above the notified turnover threshold must be reported to the Invoice Registration Portal and issued with a unique Invoice Reference Number (IRN) before it is issued to the customer. The requirement flows from Rule 48(4) of the CGST Rules 2017, which mandates the electronic generation of invoices with IRNs, and the turnover thresholds are fixed by notifications under the Act. Once generated, the invoice's details flow automatically into the GSTR-1, so the e-invoice is the single source for the outward supplies.

The e-invoice is not an extra form; it is the way the invoice itself is now issued. The IRN is generated from a hash of the invoice data, the invoice carries a QR code, and the invoice cannot be issued without the IRN. The system forces the supplier's invoice data, the GSTN's record and the buyer's ITC to agree on the same document — which is precisely why it removes the mismatches that used to surface at audit.

The cost of skipping e-invoicing is the penalty and the compliance failure together: invoices issued without the IRN are treated as not issued in accordance with the Rules, the credit to the buyer is put at risk, and the mismatches with the buyer's GSTR-2B become a demand seed. For businesses above the threshold there is no option — the invoice must carry the IRN.

This service is for businesses above the e-invoicing threshold and their suppliers. We set up the e-invoicing flow — the IRP registration, the ERP or GSP integration, the QR and IRN on every invoice — reconcile the e-invoice data with the GSTR-1, handle the exceptions (cancellation, amendment, credit notes) under Rule 48 and the related provisions, and keep the flow running as the threshold moves."