This was the point i am discussing with my friends and during my sessions of GST Audit that if the provisions of Rule 46 are not followed then penal provisions can be levied under Section 122 and Section 125. Rule 46 clearly states that on a tax invoice, the bare minimum details have to be shown and if any of the same are missing then 1st proviso of Section 122 can be enforced on the taxpayer which clearly states that penalty of Rs 10,000 per invoice. Refer to Section 122(1) (ii) talks about per invoice, so imagine if the department wants to issue notice for levy of penalty they can issue it per document which is not meeting the said provisions.
Now the same is officially clarified in the Circular #90/09/2019-GST
GST Audit report being prepared should cover this point also, so you can imagine the complexity, quantum of work involved and also the depth of knowledge required to execute it.
As per Rule 46 of the CGST Rules, a registered taxpayer can issue a consolidated tax invoice at the end of the day if the transaction value is less than or equal to Rs 200 if the recipient does not require tax invoice or recipient is a non-registered taxpayer.
As per Rule 47 of the CGST Rules, The tax invoice referred in Rule 46 in case of supply of services has to be issued within 30 days date of supply of service.
As per Rule 46 of the CGST Rules, every taxpayer has to mention the name, address, place of delivery of goods, state name, and state code on supplies made to the unregistered taxpayers if the value of the supplies is Rs 50,000 or more on the tax invoice.
As per Rule 46 of CGST Rules 2017, in the case of inward supplies of reverse charge where the inward supplies are more than Rs 5,000 per day, a consolidated tax invoice can be issued at the end of the month for all such transactions during the month.
As per Rule 46 of the CGST Rules 2017, a registered tax payer, other than a composition taxpayer can issue a consolidated tax invoice at the end of the day for all the transaction where tax invoices are not issued for a value less than Rs 200 per transaction.