E-Invoice requirements amended

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Indirect Tax Update No. 42

·       Notification No. 04/2026-CT has amended Notification No. 13/2020-CT which deals with the category of persons who are required to issue E-invoice.

·       Before the present amendment, E-invoicing was mandatory only in respect of supplies of goods or services or both to a registered person (B2B supplies) and exports, if the taxpayer’s aggregate turnover in any preceding financial year (from 2017-18 onwards) exceeded INR 5 crore.

·       While the new amendment has kept the financial threshold for e-invoicing unchanged, it has increased the scope of supplies for which E-invoicing is required.

·       In view of the new amendment, w.e.f. from 1 January 2027, in case of a taxpayer whose aggregate turnover in any preceding financial year (from 2017-18 onwards) exceeded INR 5 crore, E-invoice needs to be issued in case of the following supplies

• supply of goods or services or both to a registered person (B2B)

• supply of goods or services or both for exports

• supply of goods or services or both received from an unregistered person where the tax is payable on reverse charge basis by the recipient of such goods or services or both; or

• import of services.

·       This notification will come into force on the first day of 1 January 2027.

LKS Comments

Earlier, receipts liable to pay GST on reverse charge basis for supplies received from unregistered suppliers were required to raise self-invoice and pay tax while filing GSTR-3B. Post this amendment, an additional compliance of raising E-invoice will also be applicable for such receipts (subject to turnover in previous financial years exceeding INR 5 crores).