☐ Has supply category been identified? ☐ Has applicable sub-section been mapped? ☐ Has invoice timing been observed? ☐ Have Rule 46 particulars been compiled? ☐ For e-invoicing threshold, has IRN been generated? ☐ For Rs. 200 de minimis,…
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☐ Has supply category been identified? ☐ Has applicable sub-section been mapped? ☐ Has invoice timing been observed? ☐ Have Rule 46 particulars been compiled? ☐ For e-invoicing threshold, has IRN been generated? ☐ For Rs. 200 de minimis,…
Section 31 invoice compliance — checklist (19 items)
Section 31 invoice compliance — checklist (19 items)
☐ Has supply category been identified?
☐ Has applicable sub-section been mapped?
☐ Has invoice timing been observed?
☐ Have Rule 46 particulars been compiled?
☐ For e-invoicing threshold, has IRN been generated?
☐ For Rs. 200 de minimis, has simplified framework been applied?
☐ For Bill of Supply, has Rule 49 framework been applied?
☐ For advance, has receipt voucher been issued?
☐ For RCM, has self-invoice + payment voucher been issued?
☐ For continuous supply of services, has sub-s. (5) discipline been applied?
☐ For continuous supply of goods, has sub-s. (4) been applied?
☐ For pre-delivery sale, has sub-s. (7) been applied?
☐ Has time-of-supply coordination been done?
☐ Has GSTR-1 reporting been planned?
☐ Has Mohit Minerals constitutional framework been applied?
☐ Has Mafatlal procedural-fairness framework been observed?
☐ Has Vatika prospective-operation been applied?
☐ Has Bharti Airtel substance-over-form discipline been applied?
☐ Has the file been reviewed for audit-defensibility?
Worked examples — five live scenarios
Example 1 — Goods invoice at removal
Facts: Manufacturer ships goods to customer 10-Aug-2025. Invoice issued 10-Aug-2025.
Analysis: Sub-s. (1)(a) — invoice before / at removal. Compliance achieved.
Result: Compliant invoice. Time-of-supply 10-Aug per s. 12(2)(a).
Example 2 — Late services invoice (clause (b) trigger)
Facts: Service provided 10-Aug-2025. Invoice issued 25-Sep-2025 (46 days). Not banking / insurance / telecom.
Analysis: Sub-s. (2) + Rule 47 — 30-day window. Invoice late. Time-of-supply under s. 13(2)(b) — earlier of provision (10-Aug) or payment. If payment after, time-of-supply 10-Aug. Late invoicing penalises supplier.
Result: Late invoice triggers s. 13(2)(b) pushback.
Example 3 — E-invoicing IRN for above-threshold taxpayer
Facts: Taxpayer's AATO Rs. 7 cr. Above Rs. 5 cr threshold (effective Aug 2023). Issues invoice without IRN.
Analysis: Rule 48(4) — IRN generation mandatory. Invoice without IRN is non-compliant. Recipient cannot claim ITC. Penalty under s. 122. Practitioner advice — operationalise IRN framework.
Result: E-invoicing non-compliance has cascading consequences.
Example 4 — RCM self-invoice
Facts: Company receives legal services from advocate (unregistered for GST). Recipient liable under RCM (Notification 13/2017-CT(R)).
Analysis: Sub-s. (3)(f) — recipient issues self-invoice. Sub-s. (3)(g) — payment voucher on payment to advocate. RCM paid through electronic cash ledger. ITC claimed (subject to s. 16 conditions).
Result: RCM self-invoice + payment voucher discipline operative.
Example 5 — Continuous supply — monthly rent
Facts: Office lease. Rent Rs. 1 lakh/month. Lease agreement specifies rent due on 1st of next month.
Analysis: Sub-s. (5)(a) — ascertainable due date. Invoice on / before due date 1st. Time-of-supply earlier of invoice or payment.
Result: Continuous-supply invoice cycle discipline.
Planning and litigation strategy
Litigation defence
Cross-references