GST WEEKLY UPDATE :21/2026-27 (23.08.2026) By CA Vipul Khandhar

Spread the love

Reading Time: 7 minutes

GST e-invoice System – UPDATED FAQs:

Q. No.	Question	Answer Summary
1	What is ‘e-invoicing’?	Notified persons upload specific invoice particulars to the Invoice Registration Portal (IRP) to get an Invoice Reference Number (IRN) and QR Code.
2	How is ‘e-invoicing’ different from present system?	Businesses still create invoices in their ERPs, but now report them to IRP to get a unique IRN, digital signature, and QR Code.
3	For which businesses, e-invoicing is mandatory?	Businesses with an aggregate turnover above a prescribed limit in any preceding financial year from 2017-18 onwards.
4	What are the legal provisions governing e-invoice?	Various Central Tax notifications that amended CGST Rules, specifically Rule 48(4) and 48(5).
5	What are the advantages of e-invoice for businesses?	Auto-reporting to GST returns, auto-generation of e-way bills, standardization, reduced disputes, and improved efficiency.
6	What businesses need to do, to be e-invoice ready?	Update ERP/Billing software to enable reporting to IRP and obtaining an IRN.
7	Is an invoice/CDN/DBN valid without IRN?	No, documents issued by notified persons are legally valid only with an IRN.
8	What documents are presently covered under e-invoicing?	Invoices, Credit Notes, and Debit Notes issued by notified taxpayers.
9	What supplies are presently covered under e-invoice?	B2B supplies, supplies to SEZs, Exports, and Deemed Exports.
10	B2C (Business to Consumer) supplies can also be reported?	No, B2C supplies are not currently covered.
11	Is e-invoicing applicable for NIL-rated or wholly-exempt supplies?	No, a bill of supply is issued for these, not a tax invoice.
12	Whether the financial/commercial credit notes also need to be reported to IRP?	No, only credit and debit notes issued under Section 34 of the CGST/SGST Act.
13	Whether e-invoicing is applicable for supplies to Government Departments?	Only if the Government Department is registered under GST (has a GSTIN).
14	Applicable for invoices between two different GSTINs under same PAN?	Yes, they are treated as distinct persons.
15	Applicable for high sea sales and bonded warehouse sales?	No, they are not considered a supply of goods or services.
16	What is the applicability of e-invoice for import transactions?	Not applicable for import Bills of Entry.
17	Which entities/sectors are exempt from the mandate?	SEZ Units, insurers, banking/financial institutions, GTAs, passenger transport services, and multiplex cinemas.
18	The exemption is w.r.t the nature of supply or the entity?	It is based on the entity.
19	Do SEZ Developers need to issue e-invoices?	Yes, if they meet the turnover and other conditions.
20	Are Free Trade & Warehousing Zones (FTWZ) exempt?	Yes, they are a special category of SEZs.
21	Is e-invoicing applicable for supplies to SEZs?	Yes.
22	Does e-invoicing apply to a DTA unit if an SEZ unit under the same PAN is exempt?	Yes, if the aggregate legal entity turnover is over the limit.
23	Is e-invoicing applicable to invoices issued by Input Service Distributor (ISD)?	No.
24	Whether e-invoicing is applicable for supplies involving Reverse Charge?	Yes for supplies made attracting RCM, but not for supplies received under RCM.
25	How to know a particular supplier is supposed to issue e-invoice?	You can check enablement status on the e-invoice portal, but the obligation ultimately lies with the taxpayer based on turnover.
26	What is an Invoice Registration Portal (IRP)?	A website for uploading/reporting invoices (e.g., einvoice1.gst.gov.in).
27	Is e-invoicing voluntary for those below the turnover limit?	No, it is not allowed for non-notified persons.
28	Is there a time window to report an invoice document date to IRP?	No such validation is currently on the portal.
29	Is the digital signature (DSC) of supplier mandatory when reporting?	No.
30	Can e-commerce operators generate e-invoices on behalf of sellers?	Yes, if the sellers are notified persons.
31	What do I need to generate an e-invoice?	A system/utility to report data in JSON format to IRP and receive a signed JSON back.
32	Whether any tool is provided to report invoices to IRP?	Yes, a free offline bulk generation utility.
33	What are various modes for generation?	APIs (direct or via GSP/ASP) and Free Offline Utility.
34	Will it be possible for bulk uploading?	Yes, via the offline utility or large ERP systems.
35	Will there be any delay in generation of IRN? Can the portal take load?	No, IRNs are generated in sub-200 milliseconds, and multiple robust IRPs distribute the load.
36	Will IRP store/archive e-invoices?	No, it is a pass-through portal.
37	Will I need to enter details on a government website?	It is primarily machine-to-machine, but the offline tool can be used by those without ERPs.
38	Breakdown of internet connectivity relaxation?	The Commissioner can exempt localized areas for a specified period if needed.
39	What is e-invoice schema?	The structured, standard electronic template known as Form GST INV-1.
40	Why is an e-invoice standard/schema required?	To ensure interoperability and machine-readability across different software systems.
41	What is the basis of e-invoice schema?	PEPPOL/Universal Business Language (UBL), customized for India.
42	Is there different invoice schema for different sectors?	No, it is a single standard for all.
43	What is the file format for reporting?	JSON.
44	What are the various types of fields in schema?	Mandatory, Optional, conditionally mandatory.
45	What is ‘cardinality’?	Denotes whether a field is mandatory and if it is repetitive.
46	Can the supplier place their entity logo on e-invoice?	Yes, during final printing, but it is not part of the schema.
47	What is the maximum number of line items?	1000 line items presently.
48	How to mention taxable other charges not in taxable value?	Add them as an extra line item in the invoice.
49	How to report TCS collected under Income Tax Act?	Use the “Other Charges (Invoice Level)” field as a workaround.
50	How to report details of supplies not covered under GST (e.g., alcohol)?	Issue a separate invoice for non-GST items.
51	Differential Percentage field not available?	It is not applicable after 30.06.2020.
52	Validation w.r.t referred invoice in Credit/Debit Notes?	No linkage is built.
53	Some valid HSNs not accepted?	The HSN directory is being actively aligned across all systems.
54	Is Invoice number same as IRN?	No, the invoice number is internal; the IRN is a unique hash from the IRP.
55	How a typical IRN looks like?	A unique 64-character hash.
56	Can IRP reject a submitted invoice?	Yes, if it fails validations or was already reported.
57	What will be returned by IRP?	Only a signed JSON, no PDF.
58	Indication that IRP has registered the invoice?	Return of the signed e-invoice JSON with IRN and QR Code.
59	Can I print an e-invoice?	Yes, your ERP or the offline utility can generate a PDF to print.
60	Do I need to print IRN on the invoice?	Optional, as it is already embedded in the mandatory QR Code.
61	How will the QR Code be received?	As a string in the signed JSON, which software must convert to an image.
62	Do I need to print QR Code on the invoice?	Yes, it is mandatory.
63	Mandatory contents of printed invoice?	As per Rule 46 of CGST Rules, including the QR code.
64	Print IRP digital signature/Ack No/Date?	No mandate to print these.
65	Am I supposed to issue copies in triplicate/duplicate?	No, this is not needed when e-invoicing.
66	Possible to download and save on handheld devices?	Depends on your software; IRP does not provide future download capabilities.
67	What is the period of retention/storage?	Preserved for the period provided in Section 36.
68	Are there any penal provisions?	Yes, provided in Section 122 of CGST/SGST Act.
69	How to verify an invoice is duly reported?	Upload the JSON/QR code string on the e-invoice portal or use the verification app.
70	What data is embedded in QR Code?	GSTINs, Invoice Number, Dates, Value, Lines, HSN, and IRN.
71	What is dynamic QR Code? Relevance to B2B?	It applies to B2C invoices and has no relevance to B2B e-invoicing under Rule 48(4).
72	Is it possible to have more than one QR code?	Yes, if clearly marked to distinguish them.
73	Will the IRP send the e-invoice to the receiver?	No, the supplier must share it.
74	How will the supplier send to the receiver?	By exchanging the generated PDF (with QR Code).
75	Whether supplier’s signature is required?	Governed by Rule 46 of CGST Rules.
76	How small businesses will get the invoice from big suppliers?	Shared as a PDF via email or printed copy, similar to current practices.
77	Is carrying e-invoice print during transportation mandatory?	No, producing the QR code electronically is sufficient.
78	Can I amend details of a reported invoice?	Not on IRP; amendments must be done on the GST portal (GSTR-1).
79	Can an IRN/invoice be cancelled?	Yes, within 24 hours via ‘Cancel API’ (unless the e-way bill is active/verified).
80	Can an invoice number of a cancelled IRN be used again?	No, a new invoice number must be used.
81	Can I partially cancel a reported invoice?	No, it must be cancelled in toto.
82	Is e-way bill still compulsory?	Yes.
83	Will details be pushed to GST System?	Yes, auto-populates GSTR-1 and GSTR-2A.
84	Whether the e-way bill get auto-generated?	Yes, if Part-A and Part-B details are provided during reporting.
85	Where API integration specifications be found?	https://einv-apisandbox.nic.in/.
86	Are there more FAQs from IRP/technology angle?	Yes, available on the e-invoice and sandbox portals.
87	Who is an ASP?	Application Service Providers who route data to GST system through GSPs.
88	Will NIC provide new APIs for e-way bill?	No, the system will function as is.
89	Where can I find more material?	In the ‘e-invoice Detailed Overview’.
90	Are there awareness videos?	Yes, on GSTN’s YouTube Channel.
91	What are the channels of help and feedback?	GST Self-Service Portal or e-invoice@gstn.org.in.

2. Important Judgements:

[2026] 168 TAXMANN.COM 452 (GSTAT – KOLKATA) in the case of Agarwala’s Bitumex Private Limited[APPEAL NOS. APL/14/KLK/2026 & APL/10/KLK/2026]

Input Tax Credit — Condition for Availing — Proof of Transportation — Toll Plaza Data / Receipts

Whether non-availability of toll-plaza movement records in the supplier’s State, by itself, proves that goods were not physically transported, especially in a “Bill To–Ship To” transaction — Held, No — Whether toll-plaza receipts are a mandatory statutory condition under Section 16(2) of the CGST Act, 2017 to claim Input Tax Credit — Held, No.

Input Tax Credit / Refund — Proof of Genuine Movement & Export — Evidentiary Value of Shipping Documents

Where the Assessee established movement, receipt, and export of goods through E-way Bills, bilty copies, shipping bills, Export General Manifest (EGM) details, transporter certificates, and bank statements, whether these documents collectively outweigh Revenue’s reliance on third-party toll-plaza data — Held, Yes — Whether Customs-generated EGM and Shipping Bills serve as substantial evidence that goods received at the “Ship To” destination were actually exported — Held, Yes.

III. Refund — Accumulated ITC — Cancellation of Upstream Supplier’s Registration

Whether retrospective cancellation of registration of second-line suppliers can justify denial of ITC refund to a bona fide Assessee having no direct transaction or nexus with such upstream suppliers — Held, No — Whether irregularities committed further up the supply chain automatically prejudice a bona fide purchaser — Held, No.

Adjudication / Appellate Procedure — Fresh Allegations at Tribunal Stage — Rule 45(1) of GSTAT (Procedure) Rules, 2025 —

Whether Revenue can introduce fresh allegations or additional evidence regarding DGGI investigations, licensing requirements, or fake ITC for the first time before the Tribunal when omitted from the Show Cause Notice (SCN) and lower adjudication orders — Held, No — Read with Rule 112(1) of the CGST Rules, 2017.

Disclaimer:

This publication contains information for general guidance only. It is not intended to address the circumstances of any particular individual or entity. Although the best of endeavour has been made to provide the provisions in a simpler and accurate form, there is no substitute to detailed research with regard to the specific situation of a particular individual or entity. We do not accept any responsibility for loss incurred by any person for acting or refraining to act as a result of any matter in this publication.