There is an SEZ unit and a regular DTA unit under the same legal entity (i.e., the same PAN). In one of the financial years since 2017-18, the aggregate total turnover of the legal entity is more than notified limit (considering both the GSTINs); however, the turnover of the DTA unit is below the notified limit. In this scenario, as the SEZ unit is exempt from e-invoicing, will e-invoicing apply to DTA Unit?

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There is an SEZ unit and a regular DTA unit under the same legal entity (i.e., the same PAN). In one of the financial years since 2017-18, the aggregate total turnover of the legal entity is more than notified limit (considering both the GSTINs); however, the turnover of the DTA unit is below the notified limit. In this scenario, as the SEZ unit is exempt from e-invoicing, will e-invoicing apply to DTA Unit?

Yes, it will be applicable because the aggregate turnover of the legal entity, in this case, exceeds the notified limit. The requirement is based on ‘aggregate turnover’ on the common PAN.