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GST E-Invoices on IRP(Invoice Registration Portal)-(Report In 7 Days) w.e.f 01-05-2023, Deferred

Writer's picture: Manprit MahalManprit Mahal

The GST Network (GSTN) released advisories on 12th April 2023 and 13th April 2023 on the government portal. It has notified that some taxpayers must report invoices and credit-debit notes on the Invoice Registration Portals (IRP) within a defined time limit. The new restriction compels businesses to adopt real-time invoicing. Read on to get complete details.


What is the time limit for e-Invoicing?


The time limit to generate e-invoices on the IRP for all tax invoices issued is within seven days from the date given in the invoice and debit note or credit note.


When will the e-invoicing time limit rule apply?

The IRPs/e-invoice portals will begin validating the time limit from 1st May 2023 onwards.


Who must comply with the e-invoicing time limit?


All taxpayer businesses with an Annual Aggregate Turnover (AATO) of Rs.100 crore or more must comply with the time limit defined by the GSTN. The time limit applies to reporting tax invoices, credit notes and debit notes to any notified IRP, including any old documents unreported as on 1st May 2023.


However, the rule or validation does not apply to taxpayers whose AATO is less than INR 100 crore.


The legal status of the e-invoicing time limit

The law does not fix any time limit for taxpayers to report documents on the e-invoice portals or IRP for e-invoice generation. By default, the GST provisions on the time of supply and time limit to raise invoices would apply to any taxpayer. Whereas the restriction on the time limit of seven days to report documents on IRP is put by the GST Network/system.


Consequences of not adhering to the e-invoicing time limit


The IRP has in-built validation only to accept tax invoices, credit, and debit notes within seven days. Such taxpayers cannot generate e-invoices and will be considered non-compliant under the GST law.


If the team misses the 7-day window for e-invoicing, they must once again raise the invoice and report it to IRP. It delays reporting or auto-population of e-invoices in GSTR-1.It affects the flow of input tax credits along the supply chain due to the delay. In turn, it hurts customer relations.


The GST law imposes a huge penalty as follows-


For incorrect invoicing – Rs.25,000 per invoice (for the issue of the invoice that lacks IRN and signed QR code).

For non-generation of e-invoice – 100% of the tax due or Rs.10,000, whichever is higher, for every invoice. (where the invoice is not issued)

Impact on businesses

Applicable taxpayers must take the following steps to meet the new requirement-


Get ERPs/billing systems modified/reconfigured to add the time limit validation for tax invoices and credit-debit notes raised to get timely prompts/alerts for e-invoicing.


Latest Updates


6th May 2023


The GST department has deferred the time limit of 7 days to report the old e-invoices on the e-invoice IRP portals by three months. Further, the department is yet to announce the new implementation date.



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