GST
Penalty for not generating e-invoices
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Facts
An invoice issued without IRN is not valid under Rule 48(5). Not issuing a valid invoice can attract penalty under Sec 122, the higher of ₹10,000 or the tax involved, and procedural failures can attract general penalty up to ₹25,000 under Sec 125. Goods moving with such invoices may also be detained.
Provisions and law
- Sec 122, CGST Act 2017Penalties for offences such as invoices without supply and wrong ITC
- Sec 125, CGST Act 2017General penalty up to ₹25,000 where no separate penalty is given
- Rule 48(5), CGST Rules 2017An invoice issued without following Rule 48(4) is not a valid invoice
Analysis
Penalty exposure is per invoice, so a month of missed IRNs can be serious. The more immediate cost is commercial: buyers withhold GST and may stop orders. If you find a lapse, correct it quickly and keep records of the corrective steps.
Conclusion
- Audit a month of invoices for IRN
- Fix any lapse through IRP reporting or credit notes and reissue
- Document the correction
- Train billing staff and lock the billing system
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E-invoice onboarding and IRN generation
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