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Subject: Clarification on Applicability of E-Invoicing and 30-Day Reporting Requirement under GST

vaibhav kumar

Dear Expert,

I seek your guidance regarding the applicability of e-invoicing and the 30-day reporting requirement under GST based on the following facts:

  • My aggregate turnover in FY 2023–24 was below ?10 crore.
  • During FY 2024–25, my aggregate turnover exceeded ?10 crore only in March 2025.
  • I did not generate e-invoices for B2B transactions issued in April and May 2024, these e-invoices were generated on 10th August 2025.
  • The time limit 30-day e-invoicing reporting rule was notified as effective from 1st April 2025.

In this context, I request your guidance on the following:

  1. Does the e-invoicing mandate, along with the 30-day reporting rule, apply retrospectively to invoices issued in April and May 2024, even though my turnover was below ?10 crore at that time and only crossed the threshold at the end of FY 2024–25?
  2. Can I be held liable for non-compliance or delayed compliance in generating e-invoices for the above-mentioned period, considering that the mandate became applicable only after my turnover exceeded the prescribed limit at financial year-end?
  3. If e-invoicing and the 30-day limit are applicable in this scenario, what specific penalties or consequences might arise due to the delay in e-invoice generation for April and May 2024?

The GST portal continues to allow generation of IRNs for April–May 2024 invoices in August 2025.

Thank you for your valuable guidance.

E invoicing applicability: 30 day reporting rule does not apply to invoices issued when turnover was below the threshold. The 30-day reporting obligation for e invoicing does not apply to invoices issued when the supplier's aggregate turnover was below the prescribed threshold; the e invoicing mandate and its timing requirement become operative only after the turnover threshold is crossed, so invoices issued during the period below the threshold are not subject to the 30 day rule, and portal availability to generate IRNs later does not by itself impose retroactive 30 day timing obligations. (AI Summary)
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Shilpi Jain on Aug 31, 2025

FOr the period when you turnover has not crossed 10crores the 30 day rule will not apply.

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