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A mid-tier Indian chemical manufacturer at the Rs 450 crore annual revenue scale — a dye intermediate producer in the Vapi GIDC cluster running a portfolio across HSN Chapter 32 dyes, Chapter 32 pigments and Chapter 28/29 specialty chemistry — sits above the Notification 10/2023-Central Tax e-invoicing threshold of Rs 5 crore aggregate turnover effective 01 August 2023. Monthly outward invoice volume in the 2,500 to 4,000 range spans textile mill customers (dye buyers), paint industry customers (pigment buyers) and specialty chemistry OEMs. Every business-to-business invoice, credit note and debit note must carry an Invoice Reference Number (IRN) generated on the GSTN Invoice Registration Portal via a GST Suvidha Provider integration before the invoice is issued, along with the associated QR code embedded on the customer copy. IRN-generation failures — GSTN portal downtime, GSP outage, missing mandatory schema fields — expose the manufacturer to Section 122 CGST Act penalty of Rs 10,000 per invoice for invoices without valid IRN and to downstream customer refusal because a non-IRN invoice does not auto-populate GSTR-1 and does not flow to the recipient's GSTR-2B for ITC. The 24-hour IRN cancellation window is the only correction lever for a wrong original invoice; post 24 hours, only credit notes with their own IRN linkage can correct the position. The monthly reconciliation surface is the three-way match: ERP outward-supply register versus IRN-generation success register versus auto-populated GSTR-1 draft.
Build a per-plant per-tax-period e-invoicing reconciliation workbook keyed on the plant's state GSTIN. Extract the ERP outward-supply register for the tax period — every tax invoice, credit note and debit note raised in the period with document number, document date, customer GSTIN, taxable value, GST rate, IGST/CGST/SGST split, HSN classification. Extract the IRN-generation success log from the GSP console — every IRN generated in the period with the IRN string, generation timestamp, associated document reference, and any failure reason codes on attempted generations that did not succeed. Extract the auto-populated GSTR-1 draft from the GST portal for the tax period. Run the three-way match: ERP outward-supply register versus IRN success log versus GSTR-1 draft. Flag every ERP invoice without a matching IRN as either B2C-excluded, exempt-bill-of-supply, or Section 122 exposure candidate. Flag every IRN in the success log not in the GSTR-1 draft as an auto-population gap requiring manual insertion before filing. Flag every value mismatch as a schema-level reconciliation to close before filing. Roll forward the IRN-cancellation register (cancellations within 24 hours) and the credit-note register (original invoice IRN linked to credit-note IRN, with reason code). Recognise the Section 122 exposure per invoice-day tolerance breach with the three-day administrative tolerance window as the escalation trigger.
Plant master with GSTIN, state, PAN-level aggregate turnover flag (above/below Rs 5 crore for the threshold test), HSN chapter assignment for the plant's primary output portfolio (Chapter 32 dyes/pigments, Chapter 28 inorganics, Chapter 29 organic chemistry). GSP integration configuration with GSP name (ClearTax / Cygnet GSP / Perennial / IRIS GSP), API endpoint (in the GSP's own configuration, not fabricated in this article), authentication credentials, retry policy for IRP transient failures, batch-mode fallback for extended IRP outages. Invoice schema template per Form GST INV-01 with all mandatory fields validated at ERP-side before GSP call. IRN-generation status register with per-invoice fields for IRN string, generation timestamp, cancellation timestamp (if within 24 hours), failure reason code (if attempted and failed). Credit-note register with original invoice IRN, credit-note IRN, credit-note value, reason code. Three-day IRN-outer-limit alert on any invoice without successful IRN. GSTR-1 draft auto-population reconciliation register with the three-way match. Section 122 exposure register with per-invoice roll-forward for any invoice that breached the three-day tolerance.
A month-end per-plant e-invoicing reconciliation pack: per-GSTIN ERP outward-supply register with document-level detail, IRN-generation success log with the associated timestamps, auto-populated GSTR-1 draft, three-way variance analysis flagging any invoice missing from any of the three sources, credit-note register with original-invoice-to-credit-note IRN linkage, cancellation-within-24-hour register, and Section 122 exposure register with per-invoice quantification of the Rs 10,000 penalty risk for any invoice that breached the three-day tolerance without a valid IRN. The monthly filing pack supports the 11th-of-following-month Section 37 GSTR-1 filing with a defensible three-way reconciliation and a documented deficiency log for any manual insertions or corrections. A rolling Section 122 exposure roll-forward feeds the annual internal-audit programme and the annual assessment scrutiny defence file, with per-tax-period per-invoice attribution rather than an aggregate ITC-pool defence.
A mid-tier Indian dye intermediate producer in the Vapi GIDC cluster closes its books for a specific state-registered plant for the tax period ending 31 October 2026. The plant sits under a Gujarat state GSTIN, the parent group has run above the Rs 5 crore aggregate turnover threshold since well before the Notification 10/2023-Central Tax reduction went live on 01 August 2023, and every business-to-business tax invoice raised in the period — 3,200 invoices this month across textile mill customers taking the plant’s disperse and reactive dye output, paint industry customers taking the plant’s phthalocyanine and azoic pigment output, and specialty chemistry OEMs taking custom intermediate chemistries — must carry a valid Invoice Reference Number (IRN) generated on the GSTN Invoice Registration Portal (IRP) before the invoice is issued. The IRN plus the associated QR code are embedded on the customer PDF; the invoice-level details auto-populate the supplier’s GSTR-1 draft; the auto-populated draft feeds the 11th-of-November Section 37 GSTR-1 filing; and the customer’s GSTR-2B in November carries the invoice-level ITC entitlement under Section 16(2)(aa) of the CGST Act 2017. The reconciliation surface — a three-way monthly match between the ERP outward-supply register, the IRN-generation success log from the GST Suvidha Provider (GSP) console, and the auto-populated GSTR-1 draft — is what turns 3,200 monthly IRN events into a defensible e-invoicing chemical manufacturer Rs 5 crore threshold IRN reconciliation cycle, defensible at both Section 122 CGST Act scrutiny and at customer-side ITC audit challenges.
The reconciliation in one paragraph
A chemical manufacturer above the Rs 5 crore aggregate turnover threshold generates an Invoice Reference Number on the GSTN Invoice Registration Portal for every business-to-business tax invoice, credit note and debit note before issuing the invoice to the customer, with the IRN and QR code embedded on the customer copy. IRN generation is typically routed via a GST Suvidha Provider integration for volume operators, with the ERP raising the invoice, the GSP forwarding the payload to the IRP for registration, and the IRP returning the IRN plus QR code within a 2 to 5 second envelope in normal conditions. The 24-hour post-generation cancellation window is the only clean correction lever for a wrong original invoice; post 24 hours, corrections require a credit note with its own IRN linked back to the original invoice IRN. Where the IRN is generated successfully, the GSTN system auto-populates the invoice-level details into the supplier’s GSTR-1 draft in the applicable tax period; the supplier reviews and files by the 11th of the following month under Section 37; the recipient’s GSTR-2B then carries the invoice-level ITC entitlement under Section 16(2)(aa). Where the IRN is not generated within three days of the invoice date (an administrative tolerance window historically applied at DGGI field audits, with no explicit statutory basis), the invoice exposes the supplier to Section 122 CGST Act penalty of Rs 10,000 per invoice — and the more consequential exposure is downstream customer refusal because a non-IRN invoice breaks the ITC chain at the customer end. The monthly reconciliation is a three-way match: ERP outward-supply register versus IRN success log versus auto-populated GSTR-1 draft, with variance analysis, credit-note IRN linkage, and Section 122 exposure roll-forward all feeding a monthly filing pack per state GSTIN.
What the scenario looks like in India — safe illustrative brand persona
The Indian dye and pigment intermediate industry is anchored geographically in the Gujarat GIDC belt — particularly the Vapi cluster and the neighbouring Sarigam, Sarigam-Umbergaon and Ankleshwar clusters — where a dense concentration of mid-tier producers supplies both the domestic textile mill customer base (predominantly in Tamil Nadu, Maharashtra and Gujarat itself) and the export market for dye intermediates and pigment intermediates. The public-market listed operators at this Rs 400 to 700 crore revenue scale include Meghmani Organics (Ahmedabad-headquartered, pigments and specialty chemistry across the Vatva, Panoli and Dahej clusters), Sudarshan Chemical Industries (Pune-headquartered, one of the world’s largest pigment producers with a substantial Maharashtra manufacturing footprint), and Kiri Industries (Vadodara-headquartered, reactive dyes with a global export orientation), among the closer references. Adjacent Tier-2 dye and pigment intermediate operators — Bodal Chemicals, Bhageria Industries, Dyes India, Vipul Organics — round out the mid-tier profile. The reference persona for this article is a composite mid-tier Vapi-cluster dye intermediate producer at approximately Rs 450 crore annual revenue across a portfolio spanning disperse dyes (for polyester textile mills), reactive dyes (for cotton textile mills), phthalocyanine pigments (for the paint and printing-ink industry), and custom specialty chemistry intermediates (for downstream agrochem and pharma OEMs).
At Rs 450 crore annual revenue the producer sits comfortably above the Notification 10/2023-Central Tax e-invoicing threshold — the aggregate turnover test is applied at PAN level (not GSTIN level), so multi-plant or multi-state operators aggregate their turnover across all state registrations for the Rs 5 crore test. Monthly outward B2B invoice volume runs in the 2,500 to 4,000 range, with the mix skewed toward the textile mill and paint industry customer base — invoices to end-consumer buyers (retail packet dyes for the small-business printing market, for instance) are B2C and are excluded from the IRN-generation requirement (though the parallel dynamic-QR-code requirement under Notification 14/2020 applies to B2C invoices from Rs 500 crore-plus taxpayers, which is not the reference persona here). The GSP integration for the reference persona is with one of the established GSP providers — ClearTax, Cygnet GSP, Perennial, IRIS GSP are the mainstream options — with the ERP-side integration typically anchored on SAP FI, Oracle Fusion, Tally Prime, D365 or Zoho Books depending on the operator’s core platform choice.
The regulatory overlay — Rule 48(4), Notification 10/2023, Section 122 and Section 16(2)(aa)
Four regulatory anchors govern the chemical manufacturer’s e-invoicing cycle end-to-end. Rule 48(4) of the CGST Rules 2017 is the enabling rule — a registered person notified as a prescribed class must generate an IRN on the IRP before issuing the tax invoice, and an invoice issued in any manner other than as prescribed is not a valid tax invoice. Notification 10/2023-Central Tax dated 10 May 2023 is the threshold notification currently in force — reducing the aggregate turnover trigger to Rs 5 crore effective 01 August 2023 and bringing the mid-tier dye intermediate producer segment fully into scope for the first time. The predecessor threshold notifications — 13/2020 (Rs 500 crore trigger), 88/2020 (Rs 100 crore), 05/2021 (Rs 50 crore), 01/2022 (Rs 20 crore), 17/2022 (Rs 10 crore) — established the progressive reduction path over the 2020-2023 window and provide the context for why some mid-tier operators had already begun IRN generation before the 01 August 2023 Rs 5 crore trigger.
Section 122 of the CGST Act 2017 is the penalty exposure — a taxable person who fails to issue an invoice or bill in relation to any supply (which DGGI field practice extends to include an e-invoicing-eligible invoice issued without a valid IRN) is liable to a penalty of ten thousand rupees or an amount equivalent to the tax evaded, whichever is higher. The three-day administrative tolerance window is an unwritten convention at DGGI field audits rather than a statutory provision — an IRN generated within three days of the invoice date is typically treated as substantially compliant; IRN generated later or not generated at all is the exposure trigger. Section 37 of the CGST Act 2017 governs the GSTR-1 filing by the 11th of the following month and is where the IRN-generated invoice-level detail auto-populates. Section 16(2)(aa) of the CGST Act 2017 is the recipient-side ITC linkage — the recipient’s entitlement to ITC is conditioned on the invoice being furnished by the supplier under Section 37 and being communicated to the recipient in Form GSTR-2B. This is the commercial reason non-IRN invoices from a Rs 5 crore-plus supplier get rejected at the customer’s accounts payable gate: no IRN, no auto-population to GSTR-1, no flow to recipient GSTR-2B, no ITC — and no ITC means the customer refuses to process the invoice for payment. The Section 194Q buyer-side TDS reconciliation walkthrough at Section 194Q TDS chemical purchase Rs 50 lakh buyer-side reconciliation documents the parallel buyer-side scrutiny surface where the customer confirms the invoice is IRN-compliant before applying the buyer-side TDS.
A worked example — an illustrative Vapi dye intermediate plant at monthly close
Illustrative — the following figures represent the operating pattern of a mid-tier Indian dye intermediate producer running the Notification 10/2023 e-invoicing regime with a Gujarat Vapi-cluster manufacturing plant. Public disclosures by listed dye intermediate operators do not reveal per-plant per-month IRN-generation counts or per-invoice Section 122 exposure quantification in the granularity below; cross-verify against your own plant’s IRP GSTN portal extracts and GSP console reports before action.
The producer’s Vapi plant closes the October 2026 tax period with the following IRN-generation position:
| Reconciliation line | Count | Value (Rs crore) |
|---|---|---|
| ERP outward-supply register — total B2B tax invoices raised | 3,180 | 42.5 |
| ERP outward-supply register — B2C tax invoices (IRN-excluded) | 45 | 0.9 |
| ERP outward-supply register — credit notes (B2B) | 62 | 1.4 |
| ERP outward-supply register — debit notes (B2B) | 8 | 0.2 |
| Aggregate ERP outward-supply register — total documents | 3,295 | 45.0 |
| IRN-generation success log — B2B invoices | 3,175 | 42.4 |
| IRN-generation success log — credit notes | 62 | 1.4 |
| IRN-generation success log — debit notes | 8 | 0.2 |
| Aggregate IRN success log — total IRN-eligible documents | 3,245 | 44.0 |
| B2B invoices in ERP register without matching IRN success | 5 | 0.1 |
| — Sub-analysis: IRN generated within three days (compliant) | 3 | 0.06 |
| — Sub-analysis: IRN not generated (Section 122 exposure) | 2 | 0.04 |
| IRN cancellations within 24-hour window | 18 | 0.35 |
| Auto-populated GSTR-1 draft — invoice count | 3,240 | 43.9 |
| Auto-populated draft variance vs IRN success log | 5 | 0.1 |
| — Sub-analysis: auto-population lag (manual insertion required) | 4 | 0.08 |
| — Sub-analysis: schema-level rounding mismatch | 1 | 0.02 |
The three-way variance analysis for the October 2026 tax period surfaces two distinct reconciliation classes. First, the ERP-to-IRN gap of 5 invoices reflects the operational IRN-generation failure surface: 3 invoices had IRN generated within the three-day administrative tolerance (compliant, no Section 122 exposure), and 2 invoices had no IRN generated at all (Section 122 exposure of illustrative Rs 20,000 aggregate at Rs 10,000 per invoice under the statutory penalty formula, subject to the “tax evaded” alternative if higher). Second, the IRN-to-GSTR-1 gap of 5 invoices reflects the auto-population surface: 4 invoices sit in the IRN success log but did not auto-populate the GSTR-1 draft (typical last-two-days-of-month GSTN portal load delay; manual insertion required before the 11th of November filing) and 1 invoice populated with a rounding-level value mismatch on the IGST/CGST-SGST split (schema-level reconciliation, documented and defended at scrutiny if raised).
The credit-note register for the period captures 62 credit notes with their own IRN, each linked back to the original invoice IRN with reason codes spanning QC-failure returns from textile mill customers (28 credit notes), price-negotiation post-invoice adjustments per master supply agreement provisions with paint industry customers (19 credit notes), quantity-reconciliation short-supply adjustments (11 credit notes), and specialty chemistry batch-level rejection returns from OEM customers (4 credit notes). The 18 IRN cancellations within the 24-hour window are all wrong-customer-GSTIN or wrong-taxable-value corrections caught by the customer AP team within 24 hours of invoice raise and re-issued with fresh IRN on the corrected invoice — all cleanly reconciled and none flowing to the GSTR-1 draft.
Common reconciliation breakages
Five breakages recur across mid-tier Indian chemical manufacturers running the Notification 10/2023 e-invoicing regime and each maps to a specific control failure at either IRP-side generation, GSP-integration handshake, ERP-side data quality, or downstream GSTR-1 auto-population.
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IRP downtime during peak load causing IRN generation to fail silently. The IRP has historically seen elevated load in the last two days of each month around GSTR-1 filing deadlines and periodically on the 20th around GSTR-3B filing. Some GSP integrations do not retry failed IRP calls with sufficient persistence, leaving the invoice in the ERP as “IRN pending” indefinitely without escalation. The reconciliation discipline is a per-invoice IRN-status monitor with an automated alert at 24 hours post invoice-raise and a manual escalation to the GSP support desk at 48 hours; the three-day outer limit is the last-line trigger before Section 122 exposure attaches.
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ERP-side schema violation on mandatory Form GST INV-01 fields causing IRP rejection. Common failures include missing HSN classification at the correct 6-digit or 8-digit level (the Rs 5 crore-plus taxpayer must use 6-digit HSN as a minimum), wrong supplier GSTIN capture (especially for multi-state operators where the plant’s state GSTIN differs from the parent’s registered office GSTIN), or missing dispatch/shipping-party details on inter-state supplies. IRP-side schema validation returns a specific error code that the GSP relays back to the ERP; the ERP-side operator must fix the field and resubmit. The reconciliation discipline is a pre-submission ERP-side schema validation routine that catches the common failures before the GSP call is even made.
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Wrong customer GSTIN caught beyond the 24-hour cancellation window. The most common wrong-customer-GSTIN failure is a customer with multiple state registrations where the plant’s dispatch-location logic maps to the wrong customer state GSTIN. Caught within 24 hours: clean cancellation and fresh IRN on the corrected invoice. Caught after 24 hours: credit note (with its own IRN) plus fresh invoice (with its own IRN), and the audit trail explicitly linking credit-note IRN to original invoice IRN. The reconciliation discipline is a customer master with per-state GSTIN mapping and a dispatch-location-to-customer-state validation rule in the ERP.
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Credit-note IRN not generated in the correct tax period. A credit note raised in November 2026 for an original invoice raised in July 2026 must have its own IRN generated in November 2026 and populated in the November 2026 GSTR-1 filing (November’s Table 9B). Some ERP-side workflows attempt to backdate the credit note to the original invoice’s tax period, which creates an IRP-side rejection and a subsequent GSTR-1 auto-population mismatch. The reconciliation discipline is a credit-note register that always uses the current tax period as the credit-note date, with the linkage to the original invoice IRN captured in the credit-note schema.
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GSTR-1 auto-population gap not caught before the 11th filing deadline. The most consequential systemic reconciliation failure is the GSTR-1 auto-population lag: an invoice with a successfully generated IRN that does not appear in the auto-populated GSTR-1 draft by the review-and-file window. If the tax team files without catching the gap, the invoice does not flow to Section 37 and does not reach the recipient’s GSTR-2B — the customer then raises an ITC-mismatch dispute at their next monthly close, and the supplier must file a GSTR-1 amendment in the following tax period. The reconciliation discipline is the three-way match run before every 11th-of-month filing: ERP register versus IRN success log versus GSTR-1 draft, with manual insertion of any auto-population-gap invoices before filing. The Electronics Wave 4 sibling walkthrough at e-invoicing for electronics manufacturer under Rs 5 crore threshold documents the parallel three-way discipline in the electronics contract-manufacturing context; the mechanic transfers directly.
How a reconciliation platform handles this
A purpose-built chemicals reconciliation platform ingests the plant’s ERP outward-supply register (tax invoices, credit notes, debit notes with all Form GST INV-01 schema fields), the GSP-console IRN success log (with per-IRN timestamps and any failure reason codes), the auto-populated GSTR-1 draft from the GST portal, and the per-tax-period credit-note-to-original-invoice linkage register — and produces a monthly e-invoicing reconciliation pack per state GSTIN that runs the three-way match end-to-end, flags every ERP-to-IRN gap with the three-day tolerance quantification, flags every IRN-to-GSTR-1 auto-population gap requiring manual insertion before the 11th-of-month filing, rolls forward the Section 122 exposure register with per-invoice-day tolerance-breach quantification, and generates a defensible monthly filing pack for the tax team to review, correct where permitted, and file. The credit-note IRN linkage register, the 24-hour cancellation register, and the schema-level rounding-mismatch defence file all sit as standing dashboard controls. Match-rate improvement of 51 to 88 percent on the plant-level three-way reconciliation, combined with an ISO 27001:2022 posture and DPDP Act 2023 aligned data handling, is what makes the platform an infrastructure investment for a mid-tier Indian chemical manufacturer running 2,500 to 4,000 monthly IRN events at Rs 450 crore annual revenue scale — rather than a spreadsheet substitute that leaves the auto-population gap detection, the three-day Section 122 tolerance monitor, and the credit-note IRN linkage discipline as manual overheads on the tax team.
The cross-cluster reference at Rule 89(5) inverted-duty refund reconciliation for specialty chemicals India documents the parallel monthly-close discipline for the specialty chemistry refund workflow; the chemicals insights hub collects the full Wave 1 to Wave 4 cluster of chemical-industry reconciliation methodology. The reconciliation playbook for monthly close operations pillar and the reconciliation failure mode analysis design pillar together provide the cross-industry methodology framework. The commercial pillar for the chemicals sub-cluster is chemical reconciliation software India; the broader authority for the platform is reconciliation software India with the specialised GST reconciliation software surface for the Section 37 GSTR-1 and Section 16(2)(aa) recipient-side workflow.
The five FAQs below address the operational questions Indian chemical manufacturer indirect-tax leads and chemistry-plant controllers ask most often when building the standing monthly IRN reconciliation cycle under the Notification 10/2023 Rs 5 crore threshold regime.
Content authored by practitioners with experience at Amazon India, Intuit QuickBooks, and the Tata Group. Meet the team →
- ▸ Rule 48(4), Central Goods and Services Tax Rules 2017 — Manner of issuing invoice. A registered person to whom sub-rule (4) applies shall prepare the invoice by including the particulars therein in Form GST INV-01 after obtaining an Invoice Reference Number by uploading the information contained therein on the Common Goods and Services Tax Electronic Portal in such manner and subject to such conditions as may be specified in the notification. The invoice issued in any manner other than as prescribed shall not be treated as a valid invoice. The prescribed classes of registered persons — as progressively notified through a series of GSTN threshold notifications from Notification 13/2020 onward — must generate an IRN on the Invoice Registration Portal before issuing the tax invoice, and the invoice must carry the IRN and the associated QR code on the customer copy for the recipient to be able to claim input tax credit.
- ▸ Notification 10/2023-Central Tax dated 10 May 2023 — Amendment to Notification 13/2020-Central Tax reducing the e-invoicing aggregate turnover threshold to Rs 5 crore from Rs 10 crore, effective 01 August 2023. Every registered person whose aggregate turnover in any preceding financial year from 2017-18 onward has exceeded Rs 5 crore is required to generate an Invoice Reference Number on the IRP for every business-to-business tax invoice, credit note and debit note. Business-to-consumer (B2C) supplies are excluded from the IRN-generation requirement but B2C invoices from taxpayers above the Rs 500 crore threshold must carry a dynamic QR code under Notification 14/2020 as amended.
- ▸ Section 122, Central Goods and Services Tax Act 2017 — Penalty for certain offences. A taxable person who issues any invoice or bill without supply of goods or services in violation of the Act or Rules, or who fails to issue an invoice or bill in relation to any supply, shall be liable to a penalty of ten thousand rupees or an amount equivalent to the tax evaded, whichever is higher. Field practice at Directorate General of GST Intelligence audits treats an e-invoicing-eligible tax invoice issued without a valid IRN as a Section 122 exposure of Rs 10,000 per invoice, with the taxpayer's ability to defend the exposure resting on whether the recipient's ITC was preserved through the IRN eventually being generated within the three-day tolerance window that some field officers have historically applied administratively (no explicit statutory basis).
- ▸ Section 37, Central Goods and Services Tax Act 2017 and Section 16(2)(aa) — Section 37 governs the furnishing of details of outward supplies in Form GSTR-1 by the 11th of the following month. Where an IRN has been generated for a tax invoice, the GSTN system auto-populates the invoice-level details into the supplier's GSTR-1 draft, and the supplier reviews, edits (where permitted) and files the return. Section 16(2)(aa) of the CGST Act 2017 conditions the recipient's entitlement to input tax credit on the invoice being furnished by the supplier under Section 37 and being communicated to the recipient in Form GSTR-2B. An invoice issued without an IRN by an e-invoicing-eligible supplier does not populate GSTR-1 correctly, does not flow to the recipient's GSTR-2B, and therefore breaks the ITC chain at the customer end — the commercial reason B2B customers refuse to accept non-IRN invoices from Rs 5 crore-plus suppliers.