Is it appropriate to upload complete manual JSON file of GSTR-1 in case of those taxpayers which are subject to E-Invoicing ?
Rule 48(4) of the CGST Rules 2017, mandates certain notified registered persons to upload specified particulars of Invoice in FORM GST INV-01 and obtain an Invoice Reference Number (IRN). Currently, it is mandatory for those registered persons having an aggregate turnover of Rs. 10 Crores or more in any financial year from 2017-18 for B2B transactions.
B2B Invoices for which IRN is obtained through e-invoicing portal are auto populated in GSTR-01 of supplier, GSTR-2A of recipient and afterwards in GSTR-2B of recipient as well. These Auto populated invoices contain details such as Source (e-invoice), IRN and IRN date for identification.
Many taxpayers prepare complete JSON file of GSTR-1 using GST Offline Utility and Tool whereas many uses Third Party Accounting Software. This JSON is uploaded on portal for filing of return. In case of e-invoicing taxpayers, the earlier auto populated details via e-invoice portal in B2B section gets replaced by JSON details.
This upload results in deletion of all details of e-invoice such as Source (e-invoice), IRN and IRN date even if uploaded data matches with auto populated data. GSTN has issued an Advisory dated 03.03.22 whereby it is mentioned that any edit in auto populated data results in deletion of this by system.
The deletion of these important details makes an e-invoice seem like a normal invoice on GST portal and users cannot distinguish unless they cross check from copy of invoice. The same can also create many confusions in future and may invite reconciliations and explanations.
Better way of filing GSTR-01 in case of e-invoicing taxpayers is to-
* Cross check all auto populated B2B data with books.
* Add details for B2C, HSN summary and Documents issued etc. manually or using third party software with separate section wise JSON or skipping B2B data.
* Proceed with filling.
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