Background:
Earlier, the CBIC vide Notification No. 70/2019 – Central Tax dated December 13, 2019 notified the class of registered person required to issue e-invoice, whose aggregate turnover in a financial year exceeds INR 100 crores, which was later superseded vide Notification No. 13/2020–Central Tax dated March 21, 2020 w.e.f. 01.10.2020 (“NN 13/2020”) (as amended from time to time vide Notification No. 61/2020–Central Tax dated July 30, 2020 w.e.f. October 1, 2020, Notification No. 88/2020–Central Tax dated November 10, 2020 w.e.f. January 01, 2021 and Notification No. 05/2021–Central Tax dated March 08, 2021 w.e.f. April 01, 2021 in order to amend the turnover limit from INR 100 crores to INR 500 crores, from INR 500 crores to INR 100 crores and from INR 100 crores to INR 50 crores respectively, for the registered person).
Notification:
Now, the CBIC vide Notification No. 01/2022 – Central Tax dated February 26, 2022 has issued amendment in NN 13/2020, so as to notify such turnover limit from INR 50 crores to INR 20 crores in a following manner:
- W.e.f. April 1, 2022, the class of registered person are mandatorily required to issue e-invoice, whose aggregate turnover in any preceding financial year from 2017-18 onwards exceeds INR 20 crores.
Our comments:
Now, the e-invoicing is mandatory for the taxpayers having turnover of more than INR 20 crore from April 1, 2022.
Recently, the former Finance Secretary Ajay Bhushan Pandey has stated that, e-invoicing replaces the physical invoice and will soon replace the existing e-way bill system, and taxpayers will not have to generate separate e-way bills. Further, the government will roll out the e-invoicing system for all business-to-business (“B2B”) transactions under GST regime soon that will replace physical invoices.
In our view, in the aftermath, all the taxpayers having turnover of more than INR 5 crore, may also be required to issue e-invoice by October 1, 2022.
The Notification can be accessed at: https://www.cbic.gov.in/resources//htdocs-cbec/gst/notfctn-01-central-tax-english-2022.pdf