Dear Expert,
In the Financial Year 2024–25, my aggregate turnover exceeded ?10 crore as of March 31, 2025. However, due to oversight, I did not issue e-invoices for the months of April and May 2024.
It is important to note that during April and May 2024, the turnover had not yet crossed the ?10 crore threshold.
In this context, I would like to clarify the following:
Since the turnover crossed ?10 crore only towards the end of the financial year (i.e., March 2025), was e-invoicing applicable retrospectively from April 1, 2024 30 Days time limit?
Will any penalty be applicable for non-generation of e-invoices for April and May 2024, considering that the threshold was not breached at that time?
3. These Apr-May-24 invoice generated in 10 Aug-2025.
Kindly guide on the legal position and compliance requirements in such a scenario.
E-invoicing applies only after notified turnover threshold is crossed; not retrospective for months before the effective date If the aggregate turnover did not exceed the notified e-invoicing threshold when the April-May 2024 supplies were made, e-invoicing ordinarily would not be compulsory for those months; applicability depends on the notified threshold, effective dates and the taxpayer's turnover position on those specific dates. Where the threshold is first crossed later in the year, the e-invoicing obligation typically takes effect only from the date specified in the relevant notification or from the date the law deems the taxpayer liable, not retrospectively to earlier months when the threshold was not met. Penalties for non-issuance may be possible, but authorities often consider the timing of threshold breach, bona fide errors and late issuance; verify the exact notification, effective date and penalty provisions and obtain professional tax advice for compliance and any penalty mitigation. (AI Summary)
TaxTMI 
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TaxTMI 
