E-invoicing is not a PDF format. It is a real-time invoice-registration control that should agree with ERP, GSTR-1, customer and tax records.
Determine applicability from aggregate turnover history and prevent invoice release until a valid IRN and signed QR data are returned.
Document applicability annually.
AATO computation.
Using current-year turnover only.
From 1 August 2023, the general e-invoice threshold was reduced to ₹5 crore aggregate annual turnover, subject to notified exclusions and the any-preceding-year test from 2017-18 onward.
From 1 April 2025, taxpayers with AATO of ₹10 crore or more are subject to a 30-day reporting restriction for covered invoices, debit notes and credit notes on IRP.
An IRN can generally be cancelled only within the portal’s permitted window; later commercial corrections usually require an appropriate credit note or other lawful adjustment.
| Area | What to establish | Operating rule |
|---|---|---|
| Applicability | PAN-based AATO and exclusions. | Test all preceding years. |
| Generation | Invoice data before issue. | Block dispatch without IRN. |
| Timing | 30-day rule for ₹10 crore-plus AATO. | Monitor ageing daily. |
| Reconciliation | ERP, IRP and GSTR-1. | Resolve duplicates. |
GST control should connect five records: commercial contract, tax invoice, movement or service evidence, accounting entry and portal return. A filing that cannot be traced back to all five records is difficult to defend.
Every reconciliation should have a clear opening balance, current-period additions, corrections, reversals, payments and closing balance. Avoid unexplained plugs that make the total match but do not identify the invoice or legal reason.
Portal data is important but not conclusive by itself. GSTR-2B, e-invoice, e-way bill and ledger data should be read with the statute, rules, notifications, contracts and actual supply evidence.
Keep original source files and final filed versions. Screenshots help explain a portal event but should not replace downloaded returns, JSON, signed invoices, acknowledgements or bank records.
For material exposure, prepare a written position memo stating facts, issue, law, alternatives, conclusion, amount and approval. The memo should record uncertainty rather than hide it.
System controls should prevent a document from leaving ERP when mandatory fields, IRN, QR data, vehicle or validity requirements are incomplete.
Exception reports should be reviewed daily because many portal corrections are time-limited.
Start with the GST portal record, responsible business owner and tax working. Where the issue is operational, correct the source system and retain the acknowledgement. Where it is legal or disputed, obtain a reasoned professional position before payment, reply, refund or appeal.
Track the statutory or portal deadline separately from internal approval. Preserve helpdesk tickets, ARN, hearing requests, orders and payment records so a later reviewer can reproduce the entire path.
Before filing or replying, prepare a one-page issue sheet showing GSTIN, tax period, transaction type, amount, applicable provision, portal form, evidence owner and due date. This prevents different teams from solving different versions of the same problem.
Reconcile tax by CGST, SGST, IGST and cess rather than only by total. A total can match even when the wrong tax head, state or period has been used, which can still create interest, cash-flow and customer-credit consequences.
Build an exception register with five statuses: identified, evidence pending, vendor or customer action, tax treatment approved and closed. Every exception should retain its original amount even after correction so the audit trail remains visible.
Test the position against the counterparty’s records. Customer ITC, vendor GSTR-1, transporter data, marketplace statements and bank receipts can expose differences that are invisible in the taxpayer’s own ledger.
The final approval should record who reviewed the legal position and who approved the return, reply, payment, refund or appeal. Material GST decisions should not remain buried in informal email chains.
Run daily exception reports for documents approaching portal time limits, invalid GSTINs, failed IRNs, cancelled documents and vehicle mismatches.
System overrides should require named approval and a correction deadline. An override without follow-up turns a one-time exception into a recurring control weakness.