E-Invoice by Regular Registration to ISD (Same PAN)

[Abhijeet Mane]

Hi All, Could you please confirm whether an e-invoice is required to be generated by a regular GST registration when issuing an invoice to an ISD registration under the same PAN?

[Sadanand Bulbule]

E-invoicing is required for B2B supplies (supplies to registered persons), exports, and certain notified transactions, provided the supplier is otherwise covered by the turnover threshold.

ISD (Input Service Distributor) is indeed a registered person under GST. The fact that the ISD and the supplier GSTIN are under the same PAN does not make it an “internal transaction.”

Each GSTIN is treated as a distinct person under GST law [Section 25(4) of the CGST Act].

So, e-invoice required in this case.

[KASTURI SETHI]

Both Income Tax Act and GST Acts operate independently. A great gulf between the two ----Income Tax is direct Tax and GST is indirect tax. No relaxation/benefit is possible on the ground of PAN being the same.

I concur with the views of Sh. Sadanand Bulbule, Sir.

[Sadanand Bulbule]

Dear Sirji

Much obliged for your validation.

[Shilpi Jain]

E-invoice is required.

AI Summary

E-invoicing requirement applies to supplies to ISD under same PAN when supplier meets turnover threshold.
E-invoicing is required when a regular GST registration issues an invoice to an ISD under the same PAN if the supplier meets the e-invoicing turnover threshold; the ISD is a registered person and each GSTIN is a distinct taxable person, so common PAN does not negate invoice obligations.