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GST E-Invoicing Rules from April 2022: ₹20 Crore Threshold and Examples

The GST e-invoicing threshold became ₹20 crore from 1 April 2022, based on aggregate turnover across GSTINs under a PAN. It fell to ₹10 crore from 1 October 2022.
From TheFinanceBase Team3 min to read
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From 1 April 2022, India’s GST e-invoicing requirement expanded to taxpayers with aggregate turnover exceeding ₹20 crore. That was the threshold for the April 2022 phase—not a rule requiring every seller to create every bill on a government website. The threshold was reduced again to ₹10 crore from 1 October 2022, so the ₹20 crore figure is historical.

What changed on 1 April 2022?

Notification 01/2022-Central Tax extended GST e-invoicing to taxpayers whose aggregate turnover exceeded ₹20 crore, effective 1 April 2022. The GST Council’s record of the notification identifies the date and threshold: GST Council notification record.

The GSTN-powered Invoice Registration Portal (IRP) describes the turnover test as annual turnover above the applicable limit in any financial year from FY 2017–18 onward. It aggregates turnover across all GST registrations (GSTINs) held under the same PAN across India. See the IRP notification page for its description.

Does GST online billing mean creating the invoice on a government website?

No. In the described process, a business creates the invoice in its own billing, accounting or ERP system, then reports the required invoice data through an Invoice Registration Portal. The registered invoice copy carries an Invoice Reference Number (IRN) and a QR code. GSTN explains this distinction in its e-invoice guidance.

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“Online billing” can therefore be misleading shorthand: e-invoicing is about reporting covered invoice data for registration, not necessarily composing the original bill on the GST portal.

How the April 2022 rule worked: an example

Assume a registered business had aggregate turnover above ₹20 crore in a financial year from FY 2017–18 onward and was not covered by an applicable exemption. From 1 April 2022, it had to follow e-invoice requirements for covered supplies. It could prepare an invoice in its own system, report the required data to the IRP, and use the registered invoice details, including the IRN and QR code.

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This example explains the threshold and workflow, not the complete transaction scope. The precise documents, supplies and exclusions depend on the applicable notification and rules; do not assume a category is included or excluded based only on this example.

The threshold changed again in October 2022

₹20 crore was not the lasting threshold. Notification 17/2022-Central Tax, issued on 1 August 2022, lowered the aggregate-turnover threshold to exceeding ₹10 crore from 1 October 2022. The GST Council’s notification record provides the later change. Anyone applying the rule to a later tax period should check the currently operative notification and amendments rather than rely on the April 2022 threshold.

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How exemptions are applied

CBIC Circular 186/18/2022-GST clarifies that exemptions under Notification 13/2020-Central Tax, as amended, apply to the exempt entity as a whole, not only to a particular type of supply. The circular’s example says an exempt banking company remains exempt for its other supplies, including goods. Read the CBIC circular for that interpretation.

This clarification is not a complete list of exempt classes. For a real compliance decision, check the operative notification and its amendments for the entity’s status, covered documents and transaction categories.

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What to check before applying the rule to a business

  • Identify the relevant period: the ₹20 crore threshold applied from 1 April 2022; the threshold changed from 1 October 2022.
  • Calculate aggregate turnover across GSTINs under the same PAN, using the applicable financial-year test.
  • Check whether the entity falls within an exemption in the operative notification, including the entity-wide interpretation described by CBIC.
  • Confirm which documents and transaction types are covered under the applicable notification and rules; the threshold alone does not determine transaction-level scope.
  • If selecting or configuring billing software, assess its support for the required e-invoice data, IRP connectivity and response handling, integration with existing systems, document-category treatment, and error correction and audit trails. These are evaluation criteria, not claims about any particular vendor.

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