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 required for B2B supplies to ISD under same PAN; GST treats each GSTIN as distinct person A regular GST registration issuing invoices to an ISD registration under the same PAN must generate an e-invoice if the supplier otherwise meets the e-invoicing turnover threshold, because ISDs are registered persons and each GSTIN is treated as a distinct person under GST; the common PAN does not convert the transaction into an internal transfer or afford any relief from e-invoicing requirements. The income-tax treatment or shared PAN does not affect the independent operation of GST rules, so e-invoicing applies for B2B supplies to an ISD when thresholds are met.