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GST: Advocacy on implementation date of e-invoicing and issuance of revised schema and updated FAQs

E-invoicing is a business reform which requires significant changes to be made to ERP systems including billing systems and other allied business processes.

In this regard, GSTN recently issued API version 1.02 along with release notes which included the generation of GST e-way bill as part of Invoice Reference Number (IRN) generation and validations applied for generation of IRN, generation of e-way bill and cancellations. However, there are other aspects relating to generation of invoices which require more clarity:

– Provision for amendment of e-invoices;

– Clarity required on capability of Invoice Registration Portal (IRP) to email e-invoice to buyer;

– Manual method of generating IRNs in case of failure of IRPs or system downtime;

– Verification mechanism that will be provided to verify the QR code;

– Requirement of possession of a physical invoice for availment of tax credit, etc.

Based on our recent interactions with GST officials, we understand that the schema is expected to undergo another round of revision. Due to this, the industry is unable to freeze their requirements and develop their software functionality. ERPs and accounting systems operate on a global level and businesses have their own nuances in terms of application development process and business model requirements. It is therefore, important that adequate time is provided to work on additional requirements emerging out of the new schema and revert with any clarifications required on any aspect during this phase. Further, COVID-19 pandemic has also caused severe disruption to businesses causing considerable delay in their preparedness for a hassle free implementation of the e-invoicing under GST capabilities through their ERP/ data systems. The fact that some more changes are expected is worrisome and is causing some level of anxiety.

Given that there is just 3 months left to implement the e-invoicing capabilities, absolute clarity is required on the process flow of e-invoicing order to implement the same effectively. In this regard, we have requested the government to release revised FAQs clarifying the doubts/issues faced by taxpayers and revised final schema in synergy with APIs. Further, given the fact that updated FAQs and revised schema are still awaited, we have also sought clarity on whether the implementation date for e-invoicing continues to be October 1, 2020.

We look forward to engaging with the government on this. We will keep you posted on further developments in this regard.

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