Key Takeaways: Webinar on e-invoicing organised by NASSCOM

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Key Takeaways: Webinar on e-invoicing organised by NASSCOM

Tejasvi

@tejasvi

August 23, 2020

Public Policy

950

On August 21, 2020, the GSTN, NIC and GST Policy team in partnership with NASSCOM along with Deloitte India as Knowledge Partner organised an interactive live Webcast on e-invoicing today.

The session witnessed participation from around 150 participants. The session proved extremely useful and we were able to receive valuable insights on a wide range of issues under e-invoicing. Summarised below are the takeaways:

Applicability of e-invoicing

All B2B transactions requiring a tax invoice will require e-invoicing.
Free Trade Warehousing Zone (FTWZ) are only a special category of SEZ and would be exempted from e-invoicing.
E-invoicing would be applicable for supplies made by notified persons to SEZ.
Exemption from e-invoicing (GTA, NBFC, Banking etc.) is qua the nature of business and not entity as a whole. Intention is to exempt only such categories of taxpayers who have been given relaxation from issuing regular tax invoice. Where such categories of taxpayers generate regular tax invoice, e-invoicing would be applicable.
IRN is not required for generation of self-invoicing in case of inward RCM supplies and self-invoices for import of services. IRN is required for outward RCM supplies based on PAN based turnover threshold of INR 500 crores.
IRN is not required for invoices issued by Input Service Distributor (ISD).
IRN is applicable to all B2G (business to Government) supplies whether customer GSTIN is available. Clarification will be issued on which GST registration number to be used for supplies Government as many Government entities have the GST registration for TDS.
E-commerce operators are allowed to generate IRN on behalf of a supplier as a facilitator. Such e-commerce platform should mandatorily be registered as e-commerce operator under GST.
Voluntary e-invoicing for entities with less than 500 crore turnover is not permissible.

Generation of e-invoices

Industry Concern on specific validation that the document date can only be yesterday or today’s date: Mr Yogendra Garg acknowledged the concern over the timeline due to invoices issued in different time zones. NASSCOM will be making a detailed representation on the issues along with the need to consider relaxation for invoices raised with earlier dates due to books closure.
IRN once generated can be cancelled within 24 hours of generation. If e-waybill is generated, e-way bill is first required to be cancelled before cancellation of IRN. Once cancelled, IRN cannot be generated for same invoice again. So if IRN is cancelled, mandatory to cancel invoice and re-raise.
Printing of QR code on invoice is compulsory. However, printing of IRN is not mandatory. Printing of QR code on separate paper is not allowed. While the printed QR code shall be clear enough to be readable, the size and its placing on invoice is upto the preference of business.
Acknowledgement number and acknowledgement date returned by IRP are only for reference purpose. These particulars need not be printed on the invoice.
The signature (DSC) of the supplier is not mandatory while reporting e-invoicing to IRP.
E-way bill shall not be generated through IRP where goods are moved under multiple consignments with a single invoice. In such cases only IRN can be generated from the IRP.

Other aspects

Supplier GSTIN and place of supply (POS) state code will determine whether supply is inter-state or intra-state. Validation for the same has been incorporated in the latest API version. Ship to validation are only relevant for e-way bill purposes.
Charges which are part of taxable value and where GST is leviable can be disclosed as a separate line item as ‘other charges’.
Requirement of separate disclosure of income TCS under e-invoicing schema will be looked at by NIC. Changes required for this purpose, if any, would be intimated in due course.
Any amendment to the e-invoice beyond 24 hours have to be carried out on GST portal (through GSTR-1) and not on IRP. However, these changes will be flagged to the GST officers for their attention.
The government will notify the mechanism to provide relaxation in case of breakdown of internet connectivity in certain areas or other contingent situation.
Lower alphabets in the document number will be allowed. However, prefix “0”, “/” or “–“ in the invoice number will not be allowed.
Physical copy not required in hands of transporter. Digital copy sufficient.
IRN, once generated will be there on NIC portal for 2 days for download. After 2 days, taxpayer cannot download it from the portal.
GST return forms will not display IRN. However, if the taxpayers want to refer to IRNs in respect of transactions reported in GST returns, they can download a report from GSTN portal.

We look forward to receiving your inputs on e-invoicing aspects which needs further clarification.

Attached are the draft FAQs and the GSTN presentation discussed during the session. The webinar recording is available here.

We trust you will find the update useful.

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Tejasvi