GST: Dynamic QR Code: Request for issuance of clarification and deferral of timelines for smooth implementation

Terms of use

Terms of Use

The use of this site and the content contained therein is governed by the Terms of Use. When you use this site you acknowledge that you have read the Terms of Use and that you accept and will be bound by the terms hereof and such terms as may be modified from time to time.

All text, graphics, audio, design and other works on the site are the copyrighted works of nasscom unless otherwise indicated. All rights reserved.
Content on the site is for personal use only and may be downloaded provided the material is kept intact and there is no violation of the copyrights, trademarks, and other proprietary rights. Any alteration of the material or use of the material contained in the site for any other purpose is a violation of the copyright of nasscom and / or its affiliates or associates or of its third-party information providers. This material cannot be copied, reproduced, republished, uploaded, posted, transmitted or distributed in any way for non-personal use without obtaining the prior permission from nasscom.
The nasscom Members login is for the reference of only registered nasscom Member Companies.
nasscom reserves the right to modify the terms of use of any service without any liability. nasscom reserves the right to take all measures necessary to prevent access to any service or termination of service if the terms of use are not complied with or are contravened or there is any violation of copyright, trademark or other proprietary right.
From time to time nasscom may supplement these terms of use with additional terms pertaining to specific content (additional terms). Such additional terms are hereby incorporated by reference into these Terms of Use.

Disclaimer

The Company information provided on the nasscom web site is as per data collected by companies. nasscom is not liable on the authenticity of such data.
nasscom has exercised due diligence in checking the correctness and authenticity of the information contained in the site, but nasscom or any of its affiliates or associates or employees shall not be in any way responsible for any loss or damage that may arise to any person from any inadvertent error in the information contained in this site. The information from or through this site is provided "as is" and all warranties express or implied of any kind, regarding any matter pertaining to any service or channel, including without limitation the implied warranties of merchantability, fitness for a particular purpose, and non-infringement are disclaimed. nasscom and its affiliates and associates shall not be liable, at any time, for any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communications line failure, theft or destruction or unauthorised access to, alteration of, or use of information contained on the site. No representations, warranties or guarantees whatsoever are made as to the accuracy, adequacy, reliability, completeness, suitability or applicability of the information to a particular situation.
nasscom or its affiliates or associates or its employees do not provide any judgments or warranty in respect of the authenticity or correctness of the content of other services or sites to which links are provided. A link to another service or site is not an endorsement of any products or services on such site or the site.
The content provided is for information purposes alone and does not substitute for specific advice whether investment, legal, taxation or otherwise. nasscom disclaims all liability for damages caused by use of content on the site.
All responsibility and liability for any damages caused by downloading of any data is disclaimed.
nasscom reserves the right to modify, suspend / cancel, or discontinue any or all sections, or service at any time without notice.

For any grievances under the Information Technology Act 2000, please get in touch with Grievance Officer, Mr. Anirban Mandal at data-query@nasscom.in.

New

See all

No notification found.

GST: Dynamic QR Code: Request for issuance of clarification and deferral of timelines for smooth implementation

Tejasvi

@tejasvi

March 11, 2021

Public Policy

Rule 46 of Central Goods and Services Tax Rules, 2017 (CGST Rules), vide sixth proviso, empowers the Government to notify requirement of Quick Response (QR) code on the invoice.

Further, Notification no 72/2019-Central Tax dated December 13 2019 was issued by Central Board of Indirect Taxes and Customs (CBIC) which required a registered person with aggregate turnover exceeding INR 500 crores in a financial year, to mandatorily have a QR code on the invoice issued to an unregistered person (B2C invoice). Vide Notification 14/2020-Central Tax dated March 21, 2020 and Notification No 71/2020-Central Tax dated September 30, 2020, the above notification was superseded and date for issuance of QR Code on B2C invoice was deferred to October 1, 2020 and December 1, 2020 respectively.

On February 23, 2021, CBIC issued Circular no 146/02/2021-GST clarifying that dynamic QR Code should contain the following information:
? Supplier GSTIN number
? Supplier UPI ID
? Payee’s Bank A/C number and IFSC
? Invoice number & invoice date,
? Total Invoice Value and
? GST amount along with breakup i.e. CGST, SGST, IGST, CESS, etc.

While these much-awaited clarifications are welcomed by the industry, there are still various aspects in relation to generation of QR code which require further clarification. These include clarity on definition of “unregistered persons”, treatment of sales made through e-commerce platforms or online applications, whether banks and other RBI approved payment service providers will be making available this solution to registered persons or will the QR code be self-generated (by the respective registered persons), amongst others.

Drawing a parallel from e-invoicing which was implemented from October 1, 2020, there was a formal outreach conducted with stakeholders and clear guidelines were made available on the manner of generation of e-invoice, data points required to generate e-invoice as well as on Invoice Reference Number (IRN) generation.

However, the aforementioned Circular clarifies constituents of QR code without providing much clarity on its generation. QR Code is a business reform and not just a tax law change. It will involve significant changes to be made to ERP systems/ Point of Sales/ Cash Register System/ connected payment solution systems, which will require time for end-to-end implementation.

For a smooth and successful implementation of a critical business change of this magnitude, it is imperative that taxpayers are given adequate time to configure and test their IT systems from a date post where there is complete clarity regarding the process flow.

In this regard, we have made a detailed representation to GST Policy Wing requesting them to issue appropriate clarifications to the issues so that Industry can work towards smooth implementation of QR code requirement. Further, we have also request that a time frame of six months be given to businesses to enable them to plan and effect changes for smooth implementation of QR code requirements. For this, we have requested for extension in timelines for waiver of penalty up to 30 September 2021 (i.e. additional six months) by way of amendment in notification no 89/2020-Central Tax, dated November 29, 2020.

We will keep you posted on further developments in this regard.

Disclaimer

That the contents of third-party articles/blogs published here on the website, and the interpretation of all information in the article/blogs such as data, maps, numbers, opinions etc. displayed in the article/blogs and views or the opinions expressed within the content are solely of the author's; and do not reflect the opinions and beliefs of NASSCOM or its affiliates in any manner. NASSCOM does not take any liability w.r.t. content in any manner and will not be liable in any manner whatsoever for any kind of liability arising out of any act, error or omission. The contents of third-party article/blogs published, are provided solely as convenience; and the presence of these articles/blogs should not, under any circumstances, be considered as an endorsement of the contents by NASSCOM in any manner; and if you chose to access these articles/blogs , you do so at your own risk.

Tejasvi

Nasscom Public Policy Highlights | ...

Sudipto