Important Keyword: Notification No. 73/2020 – Central Tax, CBIC GST Notification October 2020, e-invoicing special procedure, Rule 48(4) CGST, GST INV-01 IRN generation, 30-day e-invoice rule, Section 148 CGST Act, GST e-invoice compliance India, Finodha GST compliance, e-invoicing October 2020 relief.
Words: 1269; Read time: 7 minutes.
[F. No. CBEC 20/16/09/2019-GST (Part – I)]
Government of India
Ministry of Finance
(Department of Revenue)
Central Board of Indirect Taxes and Customs
New Delhi, the 1st October, 2020
Notification No. 73/2020 – Central Tax: Seeks to notify a special procedure for taxpayers for issuance of e-Invoices in the period 01.10.2020 - 31.10.2020.
Table of Contents
GST: [To be published in the Gazette of India, Extraordinary, Part II, Section 3, Sub-section (i)]
G.S.R (E). - In exercise of the powers conferred by section 148 of the Central Goods and Services Tax Act, 2017 (12 of 2017), the Central Government, on the recommendations of the Council, Hereby notifies the registered persons required to prepare the tax invoice in the manner specified under sub-rule (4) of rule 48 of the Central Goods and Services Tax Rules, 2017, who have prepared tax invoice in a manner other than the said manner,
As the class of persons who shall, during the period from the 1st day of October, 2020 to the 31st day of October, 2020, follow the special procedure such that the said persons shall obtain an Invoice Reference Number (IRN) for such invoice by uploading specified particulars in FORM GST INV-01 on the Common Goods and Services Tax Electronic Portal, within thirty days from the date of such invoice, failing which the same shall not be treated as an invoice.
(Pramod Kumar)
Director,
Government of India
📚 Frequently Asked Questions (FAQs): Notification No. 73/2020 – Central Tax
Q1: What is Notification No. 73/2020 – Central Tax about?
Answer:
This notification specifies a special procedure for taxpayers who were required to issue e-invoices under Rule 48(4) but issued invoices manually during the transition phase of October 2020.
Such taxpayers were allowed to generate an Invoice Reference Number (IRN) within 30 days from the date of invoice by uploading details on the GST e-invoice portal.
Q2: Why was this notification issued?
Answer:
It was introduced to ensure a smooth transition to the mandatory e-invoicing system that became effective from 1st October 2020.
Many businesses faced initial technical or system-related issues integrating with the Invoice Registration Portal (IRP). Hence, CBIC allowed a 30-day relaxation period to comply.
Q3: What is the legal basis of this notification?
Answer:
The notification is issued under Section 148 of the CGST Act, 2017, which empowers the government to prescribe special procedures for certain classes of taxpayers to ensure ease of compliance.
Q4: Who were the taxpayers covered under Notification No. 73/2020?
Answer:
The notification applied to registered persons:
Who were mandated to issue e-invoices under Rule 48(4), and
Who had issued tax invoices in any other manner (e.g., manual or non-integrated software) during October 2020.
Q5: What is Rule 48(4) of the CGST Rules, 2017?
Answer:
Rule 48(4) mandates that certain registered taxpayers must prepare invoices by uploading specified details on the Invoice Registration Portal (IRP) and obtaining a unique Invoice Reference Number (IRN) before issuing the invoice.
Without the IRN, such invoices are considered invalid under GST law.
Q6: What was the timeline allowed for generating IRNs under this notification?
Answer:
Taxpayers were required to obtain the IRN within 30 days from the date of invoice by uploading the required details in FORM GST INV-01 on the GST portal.
Failure to do so would render the invoice invalid.
Q7: What was the impact of Notification No. 73/2020 on businesses?
Answer:
✅ Provided operational relief to large taxpayers.
✅ Prevented penalties for delayed e-invoice generation.
✅ Helped ensure business continuity during the early phase of e-invoice implementation.
💡 Pro Tip: Avoid such lapses by automating your GST invoicing with professional support — Finodha GST Compliance Services.
Q8: What happens if IRN is not generated within 30 days?
Answer:
If a taxpayer failed to generate the IRN within the permitted 30 days, the invoice was deemed invalid and non-compliant under Rule 48(4).
This could lead to:
ITC disallowance for recipients,
Penalties for issuing invalid invoices, and
Ineligibility for e-way bill generation.
Q9: Which forms were used for e-invoice compliance?
Answer:
The key form involved was FORM GST INV-01, which is used to upload invoice details to the Invoice Registration Portal to generate the Invoice Reference Number (IRN).
Q10: What is an Invoice Reference Number (IRN)?
Answer:
The IRN is a unique 64-character alphanumeric code generated by the GST system after successful validation of an e-invoice.
It acts as a digital verification of the authenticity of the invoice.
Q11: How did e-invoicing change the GST ecosystem?
Answer:
E-invoicing brought:
Real-time invoice reporting to the GST system,
Automated reflection in GSTR-1 and GSTR-2B,
Reduced tax evasion, and
Faster reconciliation and ITC claim accuracy.
📘 Learn more: Finodha GST Return Filing.
Q12: Which taxpayers were required to issue e-invoices during October 2020?
Answer:
Initially, e-invoicing was mandatory for taxpayers with aggregate turnover exceeding ₹500 crore in any preceding financial year from 2017–18 onwards.
This threshold was later reduced in subsequent notifications.
Q13: Does this notification still apply after October 2020?
Answer:
No.
This was a one-time transitional relief applicable only from 01.10.2020 to 31.10.2020.
From 1st November 2020, all covered taxpayers were required to comply strictly with e-invoicing provisions without any relaxation.
Q14: What are the penalties for non-compliance with e-invoicing rules after this period?
Answer:
Post the relaxation period, non-compliance with Rule 48(4) attracts penalties under:
Section 122 of CGST Act – for issuing an invalid invoice,
Section 125 – for general offences, and
Section 132 – for deliberate fraud or suppression.
Q15: How can businesses stay compliant with evolving GST e-invoicing rules?
Answer:
✅ Use GST-integrated invoicing software.
✅ Verify your e-invoices via IRP immediately.
✅ Get professional assistance for compliance setup.
📎 Start your e-invoicing compliance with Finodha experts.
🏁 Conclusion
Notification No. 73/2020 – Central Tax provided a much-needed compliance buffer during the first month of India’s e-invoicing rollout, allowing taxpayers additional time to adapt to the new system.
This step ensured smoother integration of business systems with the GST Invoice Registration Portal (IRP) and minimized disruption during implementation.
💡 Stay ahead of GST changes.
Consult Finodha GST experts today to automate e-invoicing, ensure accuracy, and maintain full GST compliance.
Download PDF: Notification No. 73/2020 – Central Tax
More Information: https://taxinformation.cbic.gov.in/
Read more interesting articles:
