E-invoicing and GST returns: the dates that changed

The test is aggregate turnover, for the whole PAN across all GSTINs, in any financial year since 2017-18. Once you cross the limit in one year you stay in, even if turnover falls later. E-invoicing covers invoices, credit notes and debit notes to registered customers, exports and SEZ supplies. It does not cover bills to consumers.

Notification 13/2020, which sets who must e-invoice, leaves out the persons listed in rule 54(2), (3), (4) and (4A) of the CGST Rules. Rule 54(4) is about a person supplying passenger transportation service, who may issue a ticket as the tax invoice. The others are banks, insurers and other financial institutions, goods transport agencies and multiplex cinemas.

Our reading: it is not settled whether a business that rents out cars with drivers (SAC 9966) is a supplier of passenger transportation (SAC 9964) for this purpose, or whether the exclusion covers the whole business or only those supplies. No clarification has been issued. Agree your position with your CA, and apply it the same way every month.

If you do not e-invoice on this ground and your turnover has crossed the e-invoicing limit in any year since 2017-18, rule 46(s) asks you to print a set declaration on your invoices saying you are not required to e-invoice.

A business with turnover of ₹10 crore or more cannot report an invoice to the registration portal once it is more than 30 days old. Without an IRN the invoice is not valid and your customer’s credit does not flow. The limit first applied to businesses of ₹100 crore and more, and came down to ₹10 crore on 1 April 2025.

In practice, an invoice dated 1 October has to have its IRN by 30 October: GSTN counts the invoice date as day one. A duty closed late in the month is fine; an invoice back-dated by weeks is not.

A company that hires cabs from unregistered owners pays the GST itself under reverse charge and issues a self-invoice. From 1 January 2027, a business that already e-invoices has to register that self-invoice on the portal too, as supply type RCMDOM, with the supplier shown as unregistered. Imported services get the same treatment as RCMIMP. The self-invoice is due within 30 days of receiving the service.

Who pays reverse charge on cab hire, and from when, is covered in Reverse charge on cab hire to companies.

• Quarterly returns (QRMP), from January 2021. With turnover up to ₹5 crore you can file GSTR-1 and GSTR-3B quarterly and pay tax monthly. Customers who want their credit earlier can be put on the invoice furnishing facility.
• GSTR-1A, from July 2024. A way to add or correct invoices for a month after GSTR-1 is filed and before GSTR-3B.
• Invoice Management System, from October 2024. Your customers accept, reject or keep pending each of your invoices before their credit is worked out. From the October 2025 period they can also keep a credit note pending, for one tax period only.
• GSTR-3B outward tax locked, from the July 2025 period. The tax you owe in GSTR-3B now comes from GSTR-1 and GSTR-1A and cannot be typed over, so a wrong GSTR-1 means a wrong payment.
• Credit only from GSTR-2B, from January 2022. You can claim credit only on bills your supplier has reported and that appear in your GSTR-2B.
• Returns time-barred after three years. The law changed on 1 October 2023, and since 1 August 2025 the portal blocks any return more than three years past its due date.
• Discounts after the invoice, from 1 November 2026. A discount you give later, by credit note, now reduces your GST once the customer reverses the matching credit, with no need for it to have been agreed before the supply. Worked through in GST invoices, advances and credit notes.

• Tax paid late: interest at 18% a year, from the day after the due date until you pay (section 50(1)).
• Return filed late: interest only on the part of the tax you pay in cash, not the part set off from credit. This covers every period since July 2017, unless proceedings under section 73, 74 or (since 1 November 2024) 74A had begun for that period before you filed.
• Credit wrongly taken and used: 18% a year from the date it was used. Credit taken but never used, because your credit balance never fell below it, carries no interest.
• Late GSTR-3B or GSTR-1: ₹50 a day, or ₹20 for a nil return, for CGST and SGST together. From the June 2021 period the total per return is capped by last year’s turnover: ₹500 for a nil return, ₹2,000 up to ₹1.5 crore, ₹5,000 up to ₹5 crore, and ₹10,000 above.