NASSCOM’s Representation on Deferment of implementation date of e-invoice system under GST

NASSCOM made a representation to Goods and Services Tax Council (GST Council) highlighting difficulties faced by IT-BPM industry in implementation of e-invoicing system on a mandatory basis from April 1, 2020 for taxpayers whose aggregate turnover exceeds INR 100 crores.

A little over four months ago, the GSTN issued the concept note and e-invoicing schema along with the FAQs. Since then, the schema has been revised/ updated 3 times (last being on 14.02.2020) and we are now expecting one more revision/ update to happen anytime. Second, the final APIs to the system were published in early January 2020. However, due to the ongoing changes in the schema, the industry is unable to freeze their requirements and develop their software functionality. Further, there are certain aspects relating to generation of invoices wherein more clarity is required.

In our last letter, we have sought deferment of the e-invoicing rollout for the very same reasons – lack of adequate time frame for the industry to meet the deadline and areas where clarifications are still awaited.

We have requested GST Council to defer implementation of the e-invoicing rollout. Given that ERP and accounting systems operate at a global level and various businesses have their own nuances in terms of the application development process and business model requirements, it is important that more time is provided.

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