Time limit to report E Invoicing.

 Government has decided to impose a time limit on reporting ‘old invoices’ on the e-invoice (IRP) portal for taxpayers having aggregate annual turnover (AATO) greater than or equal to INR 100 crores. 

 

In this regard, taxpayers having AATO equal to or greater than INR 100 crores, shall be mandatorily required to generate e-invoice within 7 days from the date of invoice.  In other words, invoice/s older than 7 days (from document date) cannot be reported on the e-invoice portal for the purpose of generating IRN.

 

The said restriction is proposed to be implemented from 1 May 2023. 

 

Non applicability of the above time limit/ restriction

 

The said time limit/ restriction shall not apply to:

 

Taxpayers having AATO less than INR 100 crores; and

Generation of e-invoice for debit notes/ credit notes

 

EY Comments

 

As a background, it may be recalled that while the modalities for implementing e-invoicing were being formulated, certain validations were envisaged to restrict generation of e-invoice for dates other than current date and previous day.  However, those validations were removed before the date of implementation of e-invoicing.

The move to impose time limit for generation of e-invoice seems to be aiming at ensuring timely compliance, resolving mis-match errors, and discouraging the cases of issuing back dated invoices.

Considering the timelines, concerned businesses are recommended to revamp their IT systems to ensure compliance with the above norms, including aligning the internal teams to ensure compliance within stipulated timelines.

Further, for the past periods (where e-invoices have not been generated), it is suggested to track such cases and regularise e-invoice non-compliances (if any) before 1 May 2023 to avoid any adverse penal consequences.