What is an e-invoicing and e-invoicing Schema?
The GST Council has approved the introduction of ‘E-invoicing’ or ‘electronic invoicing’ in a phased manner for reporting of business to business (B2B) invoices to the GST system. In continuation to that, recently the Central Board of Indirect Taxes and Customs (CBIC) notified that the e-invoice will be implemented from 1st October 2020 for the taxpayers whose turnover is more than Rs 500 crore.
What is an Invoice Registration Portal (IRP)?
E-invoices generated needs to be reported to an IRP and which will validate invoice and return back with IRN and QR Code
What is an Invoice Rerefence Number?
It is an Unique code (in technical terms hash of 3 paramaters - well known hash generation algorithm e.g. SHA256). It is combination of Supplier GSTIN, Invoice Number and Financial Year
What type of documents are covered under e-Invoice
- Invoice issued by supplier (including RCM transactions)
- Credit Note issued by supplier
- Debit note issued by supplier
- Any other document as required by the law from time to time"
Is it mandatory to generate IRN within 24 hours?
Yes, there would be time limit for e-invoice uploading for registration and the same would be notified by the Government. Without registration of e-invoice the same will not be valid. Once uploaded to the invoice registration portal (IRP), it will be registered immediately, on real-time basis
Can IRN be generated in Bulk?
Invoices must be uploaded on IRP one at a time. The IRP will be able to handle a large sequence of invoices for registration and validate them. Essentially bulk upload will be required by large taxpayers who generate large number of invoices. Their ERP or accounting system will have to be designed in such a way that it makes request one by one. For the user, it will not make any difference.
What is an E-invoice end to end work flow
"Step 1: Generation of invoice in respective ERP systems
Step 2: Generation of IRN (can be done through to respective ERPs or through IRP)
Step 3: Upload JSON file of e-invoice (along with hash/IRN, if generated) to IRP for validation
Step 4: IRP will generate / validate the hash/IRN and will add its signature and QR code return the JSON to customer
Step 5: IRP will share the data with E-way bill system and GSTN system"
What indicates that IRP has approved the e-invoice?
IRP will return the signed JSON along woth QR code. QR code to contain GSTIN of supplier, and buyer, Invoice number and date, HSN of major commodity, IRN, etc. (Note: QR code will not have status of an invoice)
Can IRP reject the submitted the invoice
IRP will validate the e-invoice and will reject if wrong GSTIN or dupllicate invoice number is found. It will return the invoice with relevant error codes without registering
What validations are conducted by IRP
IRP will validate for GSTIN correctness and whether the invoice already exists in the system
Does the IRP provide an archiving facility?
No, the details will be stored in IRP for 24 hours, and then the same can be available in GSTN in GSTR-1.
Will IRP return the signed invoice PDF / mail it to respective supplier and buyer?
No, IRP will only return signed JSON Supplier and no sharing of PDF copy or mailing of JSONs / PDFs will be done by IRP to respective buyers and sellers. PDF copy of invoice can be generated by supplier using QR code that is returned by IRP
Is the supplier allowed to distribute e-invoice to the buyer?
Yes, Supplier is also allowed to distribute JSON as well as PDF. Further, supplier is also free to share/distribute business invoice to the buyer (having multiple fields as per the business needs). However, it needs to ensure that business invoice is having all the mandaory fields as prescribed in e-invoice schema
Is printing of e-invoice PDF mandatory?
No, with machine readability the need for printing will be eliminated. Moreover OR code will enable to validate contents of an e-invoice
Whether QR will be required to be printed on the invoice
If the invoice is printed by the Company, it need to contain QR code retunrned by IRP. QR code will also contain IRN
Whether non-tax invoices / documents will be subjected to IRN
No, Bill of supply and Delivery Challan will not be required to generate an IRN
Whether IRN will be required for ISD and Export transactions
ISD invoice and ISD Credit note will be issued by an Input Service Dsitributor and IRN will be required on the same. Further, exporter also has to issue tax invoice and would require to generate IRN
Whether importers are required to generate IRN
e-invoicing / IRN generation is only applicable to creator of an invoice/document and hence, Bill of Entry will not be required to obtain an IRN
What is the process of amendment / cancellation of an e-invoice?
"E-invoice reported to IRP can be amended through GSTN and no amendment is permitted through IRP. In case of cancellation of invoice it can be done by uploading the IRN or following:
- Document type
- Document number
- Document date
Once cancelled the same number cannot be used for any other invoice "
Will e-invoice be mapped to GSTR-1 by IRP?
Yes, the IRP will push the data to the GST portal and the data will be populated in GSTR-1* of the seller.
*Subject to CBIC notification
Will Transporter ID be a part of e-invoice schema?
Yes, Transporter ID parameter will be created in e-invoice and Part A of EWB will be auto populated from e-invoice itself
Can e-commerce companies generate e-invoices for sellers on their platform
The matter has been taken up with the Government to generate e-invoices on behalf of the sellers provided the sellers explicitly authorize them to do so
Will TCS mechanism change after the implementation of e-invoicing?
No, the invoice will be issued by the supplier and not the e-commerce operator and therefore TCS is not a part of the e-commerce operator invoice.
Is physical copy of invoice needed for movement of goods
Relevant changes will be notified by the Government
Is it possible to have more than one QR code on the invoice?
Yes, but seller needs to properly annotate them to clarify which QR code represents which invoice
Large business (> 500 crores) has both B2B and B2C transactions. Will they also be required to print QR codes on the invoices?
Yes, for the B2B invoices the IRP will generate QR code. For the B2C invoices, the taxpayer has to internally generate the QR code.