In continuation of the member Consultation on Generation of Electronic Invoice on GST Portal, NASSCOM along with few member companies met GST officials dealing with the proposed “generation of electronic invoice through GST portal”. We discussed the process for generation of e-invoices in detail with an intent to ensure that the final mechanism causes minimum disruption, is implementable and is rolled out in a phased manner. Members expressed their concern that electronic invoicing might be a herculean task and duplication of effort and resources, keeping in view the fact that they already have a real-time e-invoicing system in place. This would result in serious business implications in cases where businesses generate invoices to both B2B and B2C or may be using global billing engines. Our views were well received.
In order to suggest a robust framework, the Committee has now decided to constitute 2 working sub-group to examine and recommend on policy & legal aspects as well as technical architecture for generation of e-invoice, vide issue of Office Memorandums dated May 23, 2019.
The Policy & Legal sub-group constituting of following members will examine and recommend on all legal and policy aspects of generation of e-invoice:
(a) Shri Upendra Gupta; Pr. Commissioner, GST Policy Wing, CBIC;
(b) Shri Manish Kumar Sinha, Joint Secretary (TRU-II), CBIC;
(c) Shri Ritvik Pandey, Joint Secretary (Revenue), DoR;
(d) Shri Prakash Kumar, CEO, GSTN;
The technical sub-group constituting of following members will examine and recommend on technical architecture and technical aspects of generation of e-invoice:
(a) Dr Pramod Kumar Verma, Chief Architect, UIDAI;
(b) Shri P V Bhatt, Dy. Director General, NIC, Bangalore; and
(c) Shri Nitin Mishra, Executive Vice President (Technology), GSTN
It appears that the Committee is looking to explore several technical aspects including API integration as well as adopting new mechanism for B2B supplies above a specific threshold. Further, invoice format exceptions and optional treatment for specific sectors may be on the anvil.
In light of the above, we aim to engage with the Committee as well as various State Governments to implement the e-invoicing system with least disruption. NASSCOM will further engage with the authorities in consultation with members and provide inputs on the way forward.
We look forward to your participation.