• As per Rule 48(4) of Central Goods and Service Tax Rules, 2017 (‘CGST Rules’) notified class of registered persons have to prepare invoices by uploading specified particulars of invoice (in FORM GST INV-01) on Invoice Registration Portal (‘IRP’) and obtain an Invoice Reference Number (‘IRN’)
• Registered persons will continue to create their GST invoices on their own Accounting/ Billing/ ERP Systems. However, these invoices will now be reported to IRP which would return the e-invoice with a unique IRN after digitally signing the e-invoice and adding a QR Code. A GST invoice will be valid only with a valid IRN
• E-invoicing is mandatory w.e.f. 1 October 2020 for registered persons whose Aggregate Turnover based on PAN (‘AT’) in a Financial Year (‘FY’) is more than INR 500 crores

• Documents presently covered under the E-invoice

o    Invoiceo    Credit Note; ando    Debit Note

• Supplies presently covered under E-invoice

o    Supplies to registered persons (B2B)o    Supplies to SEZs/ Exports made (with/without payment)o    Deemed Exports made

• Reporting of B2C invoices by notified person is not applicable/ allowed currently. However, they will be brought under E-invoice in the next phase. Further, E-invoice is not applicable for import bills of entry
• Entities/ sector exempted from the E-invoice mandate:

o    SEZ Unitso    Insurer or a banking company or a financial institution, including a non-banking financial companyo    Goods Transport Agency supplying services in relation to transportation of goods by road in a goods carriageo    Suppliers of passenger transportation serviceo    Suppliers of services by way of admission to exhibition of cinematograph films in multiplex screens

• There is an SEZ unit and a regular DTA unit under same legal entity (i.e. having same PAN). The aggregate total turnover of the legal entity is more than Rs. 500 crores (considering both the GSTINs). However, the turnover of DTA unit is below Rs. 100 crores for FY 19-20

In this scenario, as SEZ unit is exempt from e-invoicing, whether e-invoicing will be applicable to DTA Unit?o    Although SEZ unit is exempt from E-invoice, the same would be applicable on DTA unit because AT of the legal entity in this case is more than INR Rs. 500 crores

• E-invoice is not applicable to the invoices issued by ISD
• Accessibility of information pertaining to suppliers who are mandatorily required to issue E-invoice:

o    A list has been prepared (though not a final one), in case a taxpayer has or had prescribed AT in any FY since introduction of GST, is mandated to report E-invoice to IRP. Further, one can search the status of enablement of a GSTN on E-invoice portal by following below path:https://einvoice1.gst.gov.in > Search > e-invoice status of taxpayero    Further, in case any registered person, who doesn’t have the requirement to prepare E-invoice but still enabled on the E-invoice portal, the same may also be brought to the notice at support.einv.api@gov.in so that necessary action can be taken

• Is there any time window within which the notified person require to report an invoice to IRP, i.e.  any validation for ‘document date’?

o    No such validation is kept presently

• What are various mode for generation of E-invoice?

1. API based (integration with Taxpayer’s System directly)
2. API based (integration with Taxpayer’s System through GSP/ASP); and
3. Free Offline Utility (‘Bulk Generation Tool’, downloadable from IRP)

Further, Web based/ mobile app-based modes will also be provided in future

• In case of breakdown of internet connectivity in certain area, will there be any relaxation in the requirement of IRN?

o    A localised mechanism to provide relaxation in such contingent situations will be notified

• Can the supplier place their entity logo on E-invoice? Is that part of Schema?

o    Elements of invoice which are internal to business, such as company logo etc. are not part of e-invoice schema. However, insertion such as company logo, additional text etc., can be made by respective ERP/billing/accounting software providers

• In the e-invoice schema, the amount under ‘other charges (item level)’ is not part of taxable value. However, some charges to be shown in invoice are leviable to GST. How to mention them?

o    Such other charges (taxable), e.g. freight, insurance, packing & forwarding charges, amortization charges etc. may be added as one more line item in the invoice

• In the current schema, there is no provision to report details of supplies not covered under GST, e.g. a hotel wants to give single invoice for a B2B supply where the supply includes food and beverages (leviable to GST) and Alcoholic beverages (outside GST)?

o    For items outside GST levy, separate invoice may be given by such businesses

• In case of Credit Note and Debit Note, is there any validation w.r.t referred invoice number?

o    No, linkage with invoice is built, in view of the amended provisions of GST

• How to verify an invoice is duly reported to IRP?

o    One can verify the authenticity or correctness of e-invoice by uploading the signed JSON file or Signed QR Code (string) into e-invoice system: https://einvoice1.gst.gov.in > Search > ‘Verify Signed Invoice’o    Alternatively, with “Verify QR Code” mobile app which may be downloaded from einvoice1.gst.gov.in > Help > Tools > Verify QR Code App

• What is dynamic QR Code? Does it has any relevance for B2B e-invoicing?

o    a Dynamic Quick Response code made available to buyer through digital display (with payment cross-reference) shall be deemed to have QR code. The purpose of this Notification is to enable and encourage digital payments where buyer can scan the dynamic QR code and make payment from mobile wallet directly. The dynamic QR code, on the other hand, will have the payment details and thus ‘scan and pay’ in one go is possibleo    Further, this has no relevance or applicability to the e-invoicing in respect to B2B Supplies by notified class of taxpayers

• On generation of IRN, IRP will not send or e-mail the e-invoice to the receiver. Upon receiving signed JSON from the IRP, it is for the supplier to share the e-invoice (along with QR Code etc.) in agreed format to the receiver

• Amendments are not possible on IRP. Any changes in the invoice details reported to IRP can be carried out on GST portal (while filing GSTR-1)
• IRN/invoice reported to IRP can be cancelled. The cancellation request can be triggered through ‘Cancel API’ within 24 hours from the time of reporting invoice to IRP. However, if the connected e-way bill is active or verified by officer during transit, cancellation of IRN will not be permitted. In case of cancellation of IRN, GSTR-1 also will be updated with such ‘cancelled’ status
• Partially cancellation of a reported invoice is not allowed and it has to be cancelled completely

• With the introduction of E-invoicing, E-way bill will still be compulsory while transporting goods
• Will the e-invoice details be pushed to GST System? Will they populate the return?

o    Yes, on successful reporting of invoice details to IRP, the invoice data (payload) including IRN, will be saved in GST System and will auto-populate them into GSTR-1 of the supplier and GSTR-2A of respective receivers

• Whether the e-way bill get auto-generated?

o    In case both Part-A and Part-B of e-way bill are provided in the e-invoice schema, the details will be used to generate e-way billo    In case Part-B details are not provided at the time of reporting invoice to IRP, the same will have to be provided by the user through ‘e-way bill’ tab in IRP log in or e-Way Bill Portal, so as to generate e-way bill