As we all are aware that E-invoicing system is mandatory from 01st April, 2020 for all taxpayers whose turnover exceeds Rupees 100 crore in previous financial year, we all would have done the basic research about what is E-invoice, it’s process flow and how it’s generated. Now let us have insight of certain significant areas and challenges in E-invoicing system.
Key Points & Challenges
> Mandatory/Optional Fields:
There are multiple fields to be filled in for generation of E-invoices which are either mandatory or optional. No wonder, we can easily differentiate between them, but the key point to be noted is minute difference between codes (referred as cardinality in Schema) given for fields such as:
|0..1||Optional||Cannot be repeated|
|0..n||Optional||Can be repeated|
|1..1||Mandatory||Cannot be repeated|
|1..n||Mandatory||Can be repeated|
The registration of an e-invoice will only be possible once it has all the mandatory fields uploaded into the Invoice registration Portal (IRP). A mandatory field not having any value can be reported with NIL.
> Reporting of B2G invoices:
The type of documents to be reported to GST system includes B2B invoices, B2G invoices, Export invoices, Reverse charge invoices, credit notes and debit notes. So, there arises a need for additional classification of invoices for reporting of Business to Government (B2G) invoices. Here, the government department or agency means registered TDS Authorities.
> Availability of E-Invoices:
Most important point to be noted is that the e-invoice will be available for reference of taxpayer only for 24 hours once the e-invoice system has validated and registered an invoice.
> Amendment of E-invoices:
Amendment of E-invoice is not possible in E-invoice portal. However, the same can be amended in GST portal. Since the e-invoices generated will get auto-populated in New returns ANX-1 & ANX-2 (which is also to be implemented from 01.04.2020), tax payers have to carefully keep track of amended e-invoices separately and update the same in GST-portal to avoid erroneous reporting or mis-matches while filing their monthly returns.
> Cancellation of E-invoices:
E-invoice cannot be edited or corrected for any mistake, incorrect or wrong entry in the invoice. Only option is cancellation of e-invoice and generation of a new one with correct details. But the same can be cancelled only within 24 hours from the time of generation.
> Concept of “Sub-users”:
To overcome challenge of creating e-invoices using single login by businesses having multiple branches, option creating multiple sub-users has been introduced. A sub-user can use the same login credentials created originally and perform the actions as per the access that is given to them. However, there is a limit on the number of sub-users that can be created. A user can create maximum of 10 sub-users for every principal/additional place of business.
> Generation of Reports:
The reports can be generated only on daily basis. No cumulative or consolidated reports can be generated. However, system allows users to change the date and generate report of that particular date.
E-invoicing, a new concept under GST is to be introduced after multiple levels of meetings, conferences, discussions and feedback sessions on trial runs. But the real challenges will unfold only when it is rolled out on real-time basis. Until then let’s wait and watch……..
In this article, have tried my level best to bring out the major areas that are to be noted with regard to concept of E-invoicing system. This being my first article, would like to open-heartedly welcome all your views, suggestions and criticisms if any. Thanks a lot for bearing with me. See you once again in another interesting topic, if you all are interested.