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 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.