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GST Update - NASSCOM meeting with GSTN and GST Policy Wing on issues relating to E-commerce operators

September 7, 2020

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NASSCOM along with our knowledge partners Deloitte hosted an interactive session on e-invoicing for e-commerce operators on September 3, 2020 wherein team from GSTN & NIC and Shri Yogendra Garg, Principal Commissioner, GST Policy were present.

The session proved extremely useful and we were able to receive valuable insights on how e-commerce operators need to proceed with e-invoicing for sellers.  Following key clarifications were provided during our discussion:

  • E-commerce operators can raise e-invoices on behalf of their sellers using their TCS GSTIN.  The steps to register on e-invoice portal and raise e-invoices were presented in the form of the attached presentation by NIC.  They mentioned that the detailed guidelines will be updated on the e-invoice portal in a couple of days.
  • No authorization mandated from sellers, however, recommended to have an authorization in writing for raising e-invoices on behalf of sellers.
  • In case the e-com GSTIN is used, the data will be accepted by IRP and it will also flow to GSTR-1 of seller as well as GSTR-8 of the e-commerce operator.
  • Offline transactions – On the query of whether offline transactions such as stock transfer from warehouse, scrap sales etc can be reported, it was explained that there is no embargo.  However, this could have TCS reporting issue as such offline sales also would flow to TCS return.  GSTN has explained that they will look into the same.
  • Possible multi layered structure – Given that the sellers may have their own sales, sales through online as well as other e-commerce operators, GSTN is yet to explore a multi-layered structure (e-commerce operator, GSP, other service providers for the same seller).
  • IP usage – On the issue of IP usage, GSTN clarified that e-commerce operator can use the same IP for all its registrations under the same PAN.  Using the IP for e-commerce seller e-invoicing will not restrict them from using it for their own e-invoicing.
  • Reporting, post removal of T+1 validation – On a separate note, while thinning for the removal of the T+1 validation for e-invoicing, a query was raised on how the data flow to GST returns would work. GSTN explained that the matter has already been picked up and is under discussion with CBIC.

We will be shortly filing an updated representation document on the open items.

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


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