E-invoice in GST Regime – Frequently Asked Questions

 

The Central Board of Indirect Taxes and Customs (‘CBIC’) has recently issued Frequently Asked Questions (‘FAQs’) clarifying important aspects in relation to the E-invoice system under the GST regime. We have hereinbelow summarized some of the key aspects clarified for your reference:

S.No. Topic Questions Response
1. Invoice Registration Portal (‘IRP’) – Bulk e-invoice Is bulk submission of e-invoices to IRP allowed? Application Service Provider (‘API’) will allow upload of JSON files. The invoices shall be accepted one at a time, though they can be uploaded sequentially. Further, the system shall be designed in such a manner so as to scale and respond to API requests enabling the acceptance of millions of invoices per day
2. IRP What indicates for the supplier (and respectively) buyer that IRP has approved the e-invoice? The IRP will respond with a signed Invoice Reference Number  (‘IRN’) and a Quick Response (‘QR’) Code with digital signatures of IRP to the seller
Will the IRP return both signed JSON and signed PDF? IRP will return only the signed JSON
Whose digital certificate will be used to sign the invoice? The signature will only be of IRP
How can the digital signature be uploaded into IRP? The digital certificate is not required and only the signed (optional) JSON will be received at the IRP
3. Business Query Is the supplier allowed to distribute the e-invoice to the buyer? Yes.
Which form of E-invoice is allowed to be distributed- the JSON, the PDF or both? As deemed fit by the seller. However, in order to make use of the e-invoice scheme, it should be shared in the JSON format so that it can be read by the ERP of the buyer and straight away visible in the buyer’s relevant books.
4. Other Documents What are the requirements for other document types, such as credit/debit note, Input Service Distributor (‘ISD’) invoice, bill of supply, delivery challan, receipt voucher, advance receipt, payment voucher, self-invoice? ISD invoice and ISD credit note are the documents issued by ISD, therefore, IRN will be required on these documents.
What applies to export transactions / invoices? Exporter has also to issue tax invoice, which is required to be reported like any other transaction. Hence, it is applicable on export invoices too.
What are the requirements for import transaction/invoices? Creator of document is required to generate the e-invoice, hence, bill of entry generated by customs on import of goods does not require IRN.
5. Amendments Can invoice uploaded on IRP be amended? If yes, how will the amendment be done? E-invoice reported to IRP will be uploaded to the GST system. Any amendments to be made will be, thus, done on the GST system only and not on the IRP.

 

However, if the business wants to cancel an already reported invoice, he may do so uploading specified documents.

 

 

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E-way Bill

 

Will the e-invoice schema have the Transporter ID so that the e-way bill can also be generated using this? Transporter ID parameter will be created in the e-invoice schema. Part A of the e-way bill will be populated from the e-invoice schema data itself.
Is it possible to have > 1 QR code on the invoice? If seller wishes to place more than 1 QR code, then he needs to properly annotate them to clarify which is which.
7. E-Commerce Can e-commerce companies generate invoices for the sellers on their platform? The e-commerce operators as authorized by the Government can generate the invoices on behalf of the sellers, provided the sellers explicitly authorize them to do so.
8. ANX 1 What will happen if ANX 1 is updated after the invoice has been uploaded into the IRP? Both the versions will be kept and available in the GST system, as part of the e-invoice registration at the IRP and in the GST system, when being amended.
9. Schema When is the section on delivery or invoice period mandatory? In case of continuous supply of services.
For “billing name” the description of the schema says ‘buyer legal name’ but the explanatory notes says ‘trade name of buyer’. Pl clarify which is to be used. Buyer legal name is to be used.
Please explain the mechanism of handling TCS by ecommerce players. Where and how will this be reported? Invoice is issued by supplier and IRN will also be obtained by the supplier whereas e-commerce operator facilitates such supply and is not required to obtain IRN. Therefore, TCS is not a part of the invoice of e-commerce operator.

 

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