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.

AI Summary

E-invoicing mandatory only if preceding FY turnover exceeded Rs.5 crore; no penalties for April-May 2024 otherwise The forum advises that e-invoicing threshold was reduced to Rs.5 crore effective 1 Aug 2023 and applicability is determined by turnover in a preceding financial year: e-invoicing applies in the subsequent FY only if relevant preceding FY turnover exceeded Rs.5 crore. If the taxpayer's turnover in years before FY 2024-25 did not exceed Rs.5 crore, e-invoicing was not mandatory for April-May 2024 and penalties should not apply for those months; if a preceding year did exceed Rs.5 crore, penalties (noted by respondents as Rs.20,000 per instance or tax evaded, whichever higher) could be invoked. Generating the missed e-invoices now may mitigate the issue.