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E-invoicing system requires modifications to the accounting/billing/ERP software as a one-time action at the time of implementation. It will help in the smooth functioning of the business. The following are possible changes and some recommendations for ERP software providers as well as the taxpayers to adopt and implement the e-invoicing system:
The list of ERP changes for smooth e-invoicing implementation are as follows:
30th June 2021
The CBIC has issued a notification seeking to waive the penalty imposed on non-compliance of dynamic QR code provisions for B2C invoices between 1st December 2020 and 30th September 2021.
1st June 2021
CBIC has notified vide Central Tax Notification no.23 dated 1st June 2021 that the e-invoicing system shall not apply to a government department and local authority.
30th March 2021
The CBIC has issued a notification seeking to waive the penalty imposed on non-compliance of dynamic QR code provisions for B2C invoices between 1st December 2020 and 30th June 2021, provided the said person complies with the provisions of the said notification from 1st July 2021.
8th March 2021
The CBIC has notified that e-Invoicing will be applicable from 1st April 2021 for businesses with an aggregate turnover of more than Rs.50 crores (in any financial year from FY 2017-18 onwards).
29th November 2020
The CBIC issued a notification seeking to waive the penalty imposed on non-compliance of dynamic QR code provisions for B2C invoices between 1st December 2020 and 31st March 2021, provided the eligible registered person complies with these provisions from 1st April 2021.
10th November 2020
The taxpayers having an aggregate turnover exceeding Rs.100 crore should implement e-invoicing from 1st January 2021.
1st October 2020
The applicable taxpayers have been given a grace period of 30 days for generating an Invoice Reference Number (IRN). However, this grace period is valid for the invoices issued between 1st October 2020 to 31st October 2020.
30th September 2020
Now, the aggregate turnover should be checked from FY 2017-18 till FY 2019-20, for checking the applicability of e-invoicing. Also, the date of implementation of the dynamic QR Code for B2C invoices has been extended until 1st December 2020.
30th July 2020
1. A new refined format of e-invoice has been notified by CBIC adding 20 new fields and removing 13 fields. Certain fields have undergone changes in character length as well.
2. e-Invoicing system shall apply to those taxpayers with an annual turnover exceeding Rs 500 crore instead of Rs 100 crore.
3. Special Economic Zones (SEZ) units shall also be exempted from issuing e-invoices.
23rd March 2020
The implementation of e-invoicing and the QR code has been deferred to 1st October 2020.
Exemption from e-Invoicing and QR code has been granted to sectors such as insurance, banking, financial institutions, NBFCs, GTA, passenger transportation service and movie tickets.
In order for the invoices to be easily validated before being submitted to the IRP portal, ERP system should have integrated all the necessary fields as per the schema notified by the CBIC. In other words, the invoice issued by the billing/ERP software must cover all the mandatory fields stipulated by the GST law.
With effect from 1st October 2020, taxpayers with an aggregate turnover of more than Rs.500 crores in any preceding financial year (from 2017-18) must generate Invoice Reference Number (IRN) on the Invoice Registration Portal (IRP) for all B2B transactions.
Further, with effect from 1st January 2021, this extends to turnover of more than Rs.100 crore. Hence, the ERP will have to generate the JSON file and upload the same on the IRP separately. Further, the IRP would generate a QR code which needs to be printed on the invoice. Further, from 1st December 2020, taxpayers with an aggregate turnover of more than Rs.500 crore in any of the previous financial years (starting from 2017-18) will have to also provide for the dynamic QR code in their B2C invoices.
The ERP software will have to classify a particular transaction into the following categories:
Details required as per Part A of the e-way bill will need to be entered only once.
The IRP will use a hash generation algorithm (SHA256) to generate an IRN for each invoice. The parameters for the hash generation would be:
Once the IRN for a particular invoice is successfully generated, the same should be printed on the hard copy of the invoice. Note: All the zeroes prefixed to the document number parameter will be ignored for hash generation.
From 1st January 2021, taxpayers with an aggregate turnover of over Rs.100 crore in any previous financial years (starting from 2017-18) must get the QR code printed on their B2B invoices, as issued by the IRP. From 1st October 2020, taxpayers with an aggregate turnover of more than Rs.500 crore must have QR code printed on their tax invoice. Further, in case their aggregate turnover in the previous financial year is Rs.500 crore or more, the same needs to be followed for B2C invoices too. Necessary changes must be incorporated into the IT systems.
While it is not compulsory for the taxpayer to digitally sign the JSON being uploaded into the IRP, the IRP will digitally sign JSON and send it back to the taxpayer.
In order to fully integrate with the e-invoicing system, the ERP software should provide for data exchange with the use of the following APIs:
Some best practices relating to the use of API have been prescribed:
In order to use any of the abovementioned APIs, it is necessary to get authenticated. Authentication is done by entering client ID and password. The password would be encrypted using an e-invoice public key. All taxpayers covered under one PAN would be given a single client ID and password.
The e-Invoicing system has allowed the sales invoice details to be autopopulated from the IRP onto the GSTR-1 on the GST portal. One must note that not all details will be autopopulated as B2C supplies are out of scope. Hence, it necessitates the need to reconcile autopopulated GSTR-1 or the IFF with the sales register and identify any gaps, so that no document is missed out before filing GSTR-1 for a month or quarter.
The ERP software should provide a way to link the invoices generated to the accounts payable and accounts receivable module to ensure good debtors management and timely settlement of invoices. Further, ITC could be denied if payment is not made within 180 days of the date of invoice. Hence, ERP software can also incorporate payment reminders in this regard.
The ERP software needs to, first of all, ensure that a unique document number is being assigned to every invoice. Further, even in case of a cancelled invoice, the same document number used by the cancelled invoice should not be used elsewhere. Hence there should be a system for tracking of cancelled invoices and cancelled e-way bills generated based on invoices. Invoices may only be available for cancellation on the IRP for 24 hours. Beyond 24 hours, the ERP software has to redirect the taxpayer to the GST portal to cancel the invoices.
Amendments either can be made by cancelling old invoices and uploading JSON of new invoices and generating a fresh IRN or by issuing necessary credit notes/debit notes. There should be a way to link such credit notes/debit notes to the original invoices that needed amendment.
The IRP will not store invoices. The ERP software will have to provide for storage of invoices for easy reference at a future date. Further, much older invoices will need to be archived into a separate backup medium.
The ERP program should be able to auto-share such an invoice with the receiver after creating the IRN and signing the QR code for the generated invoice. This will assist the parties involved in the claim for the precise input tax credit (ITC) and the GST return file. Likewise, there must be feature to identify, record and store the e-invoices received from the respective suppliers.