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.

AI Summary

E-invoicing applies from April 1, 2025 after crossing Rs 10 crore threshold; late IRN portal aids regularisation, seek tax advice A taxpayer who crossed the Rs.10 crore aggregate turnover threshold only in March 2025 would generally fall within the e-invoicing mandate from 1 April 2025, not retrospectively to invoices issued in April-May 2024 when the threshold was not yet met. The portal allowing late IRN generation suggests regularisation is operational, but risk remains of departmental scrutiny: potential consequences include interest and late payment liabilities if tax positions change, penalties or late-fee assessments for invoice/reporting non-compliance, and practical consequences for recipients' input tax credit. Whether enforcement occurs depends on facts and departmental view; obtain specialist tax advice to regularise and mitigate exposure.