Query Regarding Applicability of E-Invoicing and Penalty for Non-Issuance in FY 2024-25

[vaibhav kumar]

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:

1. 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?

2. 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.

[Shilpi Jain]

From 1st Aug 23 the limit has been revised to Rs. 5 cr and no more 10cr.

E-invoice will be applicable in a FY after such date only if in any of the PRECEDING FY the agg. t/o crosses 5cr.

So if in this year assume your turnover crossed 5 cr then in the next year only e invoice becomes applicable.

[Pinnacle Tax Advisor]

At the outset, please note that the threshold limit for e-invoicing has been reduced to ?5 crore from the earlier limit of Rs. 10 crore w.e.f. 01 Aug 2023. (Notification 10/2023 –Central Tax)

Further, if the turnover in any preceding financial year exceeds Rs. 5 crore, the taxpayer becomes liable to issue e-invoices.

In your case, if your turnover did not exceed Rs. 5 crore in any year prior to FY 2024–25, then you would be liable to implement e-invoicing only from April 2025 onwards.

However, if the turnover had crossed Rs. 5 crore in any earlier year, your company may be liable for a penalty of Rs. 20,000 per instance of non-compliance, or the amount of tax evaded, if any—whichever is higher.

[Raam Srinivasan Swaminathan Kalpathi]

Please try taking the left out months e-invoices now.  Time limit of 30 days for taking e-invoices is applicable only for taxpayers with greater than 10 crores turnover is only applicable from Apr 1, 2025.  Problem should get solved with this. 

AI Summary

E invoicing applicability depends on prior year turnover; missed invoices may incur penalties, remedial issuance advised. The document explains that mandatory e invoicing depends on whether the taxpayer's aggregate turnover in a preceding financial year exceeded the revised regulatory threshold effective August 2023; if it did not, e invoicing would not have been required for April-May 2024 and becomes applicable only from the later year, whereas prior breach of the threshold would attract penalty exposure for non issuance. Respondents advise remedial generation of the missed e invoices and note a time limit rule for larger taxpayers applicable from a subsequent implementation date.