Where an E-Invoice/IRN has been validly generated on 11th at 3:00 PM, i.e., prior to the due date and time prescribed for filing GSTR-1, compliance under Rule 48(4) of the CGST Rules stands duly discharged. The subsequent delay in auto-population of such invoice data on the GST portal is a system-driven GSTN/IRP synchronization issue and does not affect the legal validity of the invoice or the underlying compliance.
It is an established GSTN functionality that E-Invoice data may auto-populate in GSTR-1 on a T+1/T+2 basis. Accordingly, invoices for which IRN has already been generated may reflect on the portal only on the following day. In such circumstances, where the invoice is manually reported in GSTR-1 to avoid lapse of the statutory filing timeline, the inability to manually populate IRN particulars in GSTR-1 is merely a technical limitation of the portal and cannot be construed as non-compliance.
Therefore, manual reporting of the said invoice in GSTR-1 is legally tenable and procedurally valid, provided that:
(i) the IRN was duly generated prior to filing of GSTR-1;
(ii) the invoice particulars reported in GSTR-1 are identical to the data uploaded on the IRP; and
(iii) the IRN acknowledgement, QR code and related E-Invoice records are duly maintained for audit and reconciliation purposes.
In the event of any departmental scrutiny, the IRN generation timestamp and IRP records shall constitute conclusive evidence of statutory compliance. Mere non-reflection of IRN particulars in GSTR-1 owing to portal auto-population delay does not give rise to any substantive contravention under the GST law.