The Government vide the Notification No 14/2020 – Central Tax dated 21st March 2020 made it mandatory for taxpayers with aggregate turnover exceeding INR 500 crores to mention Dynamic QR code on B2C invoices. However, the Government vide Notification No 6/2020 – Central Tax dated 30th March 2021 waived off the penalty for non-compliance with the Dynamic QR code requirement provided the same is complied with w.e.f from 1st July 2021.
To address the queries of the taxpayers surrounding various issues in compliance with Dynamic QR code requirement, the Government issued Circular No 146/2/2021-GST dated 23 February 2021. How the taxpayers still had some additional queries which were brought to the notice of the Government and to resolve those queries, following additional clarifications have been issued by vide Circular No 156/12/2021-GST dated 21st June 2021:
| S. No. | Issue | Clarification as provided in the Circular |
| 1. | Whether Dynamic QR code required on invoices issued to taxpayer registered under Section 25(9) of CGST Act (GST Act) i.e. taxpayer who has obtained Unique Identity Number (UIN)? | Since the definition of registered person (Section 2(94) of GST Act) specifically excludes person having UIN, a person with UIN will be treated as unregistered taxpayer for the purpose of GST. Consequently, any invoice issued to UIN holder will be treated as B2C invoice and thus, have to comply with Dynamic QR code requirements. |
| 2. | Where the UPI ID is linked to the bank account of the person collecting the money, is it mandatory to mention to separately mention bank account number and IFSC code in the Dynamic QR code? | Since the UPI ID is already linked to the bank account of the person collecting the money, requirement to separately mention bank account number and IFSC code on Dynamic QR code is not mandatory. |
| 3. | Where payment for supply is collected by person other than supplier (for instance Electronic commerce operators like Amazon, Flipkart etc.), can UPI ID of the person collecting the payment (authorized by supplier for such collection) be provided instead of the UPI ID of the supplier itself? | Yes, in such cases, the UPI ID of the person authorized to collect payment on behalf of the supplier can be provided in the Dynamic QR code instead of UPI ID of supplier itself. |
| 4. | Whether Dynamic QR code is required to be printed on invoice in the scenario where recipient of service is located outside India but the place of supply is in India and the payment for such supply is received in foreign exchange, through RBI approved mode of payment? | Since the recipient is located outside India and cannot use the Dynamic QR code for making the payment to the Indian supplier, the invoice can be issued without the Dynamic QR code. |
| 5. | In case of over the counter sales, it happens that payment is received from customer on counter by displaying Dynamic QR code on digital display whereas the invoice alongwith invoice number is generated on the processing system of the supplier after receipt of payment. However, every payment received by the supplier has a Unique ID/ reference number linked with the invoice for said transaction.
In such cases, whether Unique Order ID/ reference number can be provided in dynamic QR code instead of invoice number? |
In such case, the unique order ID/sales reference number, which is uniquely linked to the invoice issued for the said transaction, may be provided in the Dynamic QR Code provided the details of such unique order ID/ sales reference number linkage with the invoice are available on the processing system of the supplier and the cross reference of such payment along with unique order ID/ sales reference number are also provided on the invoice. |
| 6. | Where the supplier has already received the part payment for supply as advance or adjustment (for instance through voucher or discount coupon etc.) before generation of Dynamic QR code, what should be the invoice value in the Dynamic QR code? | Where the part payment is already received or adjusted by the supplier before generation of Dynamic QR code, while generating the Dynamic QR code, the supplier should provide the balance value (Total value – advance received / adjustment). This is because the Dynamic QR code is generated to enable the recipient to scan and make payment in respect of supply and since part payment has already been received/ adjusted, logically also, the QR code should be for the balance value.
Note: The total invoice value with details/ cross reference to advance received/ adjustment made and the balance amount to be paid should be provided on the invoice by the supplier. |
Disclaimer: The above article summarizes the clarifications issued by the government with respect to Dynamic QR code. Please refer to the latest law and consult the author before forming an opinion basis the information provided above as tax laws are subject to frequent changes. The author is not responsible for any issues arising as a result of opinion based on the above article without consultation.
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