E - Invoicing

[Kaustubh Karandikar]

XYZ (Proprietory Concern) owning sweet shops and having more than ₹ 100 Crore turnover in a financial year. Most of their supplies are to B To C and very few i.e. 5 to 10 transactions in a month are to B To B. Are they required to start e – invoicing from 01.01.2021 for B To B supplies only or for all the transactions i.e. B To C as well as B to B or since B To B is very negligible, they need not follow e – invoicing system?

[Rajagopalan Ranganathan]

Sir,

As per Notification No.13/2020– Central Tax dated 21st March, 2020 -

"registered person, other than [a Special Economic Zone unit and]1 those referred to in sub-rules (2), (3), (4) and (4A) of rule 54 of the said rules, whose aggregate turnover in any preceding financial year from 2017-18 onwards exceeds five hundred crore rupees / [one hundred crore rupees , as a class of registered person who shall prepare invoice and other prescribed documents, in terms of sub-rule (4) of rule 48 of the said rules in respect of supply of goods or services or both to a registered person or for exports.

The only condition is both supplier and recipient are registered under CGST Act, 2017. In respect of B@C transaction if both the supplier and recipient are registered than e-invoice is applicable.

[Ganeshan Kalyani]

Sir, the taxpayer is required to do e-invoicing for their B2B supply and for B2C it is not required.

In my view, in GST , B2B means supply to a registered taxpayer and B2C means supply to an unregistered taxpayer.

[KASTURI SETHI]

I support the views of both experts. I further clarify that when we talk of 'recipient' as a registered person, it is very much clear like sunshine that the said recipient is registered for the purpose of business. Sh.Ganeshan Kalyani has also cleared this point on the same page

AI Summary

E-invoicing applicability requires B2B supplies to registered recipients when turnover threshold exceeded; B2C supplies generally excluded.
E-invoicing is required of registered persons whose aggregate turnover in any preceding financial year from 2017-18 onwards exceeds the notified threshold, for supplies to other registered persons and for exports. The requirement applies only where both supplier and recipient are registered under the CGST framework. B2B denotes supplies to registered taxpayers and attracts e-invoicing when the supplier meets the turnover criterion; B2C denotes supplies to unregistered persons and is generally outside the e-invoicing mandate.