All about Dynamic QR Code on B2C invoices- Latest Notification No. 06/2021 – Central Tax Dated- 30th March, 2021

The QR Story:-

The story started for QR code as early as 28/June/2019, when for the first time, ‘QR’ found a mention in the Rule 46, as its 6th proviso.

Interestingly, notification 31/2019 (CGST 4th Amendment Rules, 2019) had Rule no. 5 pertaining to QR code on tax invoices, but ‘wasn’t notified within that notification‘ until another Notification was issued to notify this Notification.

Rule 5: In the said rules, in rule 46, after the fifth proviso, with effect from a date to be notified later, the following proviso shall be inserted, namely:-

“Provided also that the Government may, by notification, on the recommendations of the Council, and subject to such conditions and restrictions as mentioned therein, specify that the tax invoice shall have Quick Response (QR) code.”.

This provision of QR code was then notified (w.e.f. 1/Apr/2020) vide NN 71/2019-CT on 13/Dec/2019.

Notifications w.r.t. QR on B2C Invoices:-

Lets cut the clutter:-

Notification No. Date of issue: w.e.f. Concerning Eligibility/ by whom to be complied
Notification No. 14/2020– Central Tax Dated –  21st March, 2020 21/March/2020 : w.e.f 1/Oct/2020 B2C Invoices to have Dynamic QR Code “Not All” businesses, but excluding some (i.e. Rule 54(2),(3),(4) and (4A)),

and

having Agg. turnover greater than Rs. 500 Cr., “in a Financial Year”.

Notification No. 71/2020 – Central Tax Dated 30th September, 2020 30/Sept/2020 :

w.e.f 1/Dec/2020

Amends NN 14/2020-CT listed above “in a Financial Year” replaced with “in any F.Yr. from 2017-18 onwards”.

Also amended date of effect of NN 14/2020-CT, from 01 Oct 2020 to 01st Dec 2020, for printing Dynamic QR on B2C invoices.

Notification No. 89/2020 – Central Tax  Dated- 29th November, 2020 29/Nov/2020 Penalty waiver for non-compliance of QR Code on B2C Waives penalty u/s 125 CGST Act (Rs.25,000) for non-compliance of QR code printing on B2C invoices, until 31/Mar/2021,

Provided that the qualified person complies with the provisions of the said notification from the 01st day of April, 2021

Notification No. 06/2021 – Central Tax Dated- 30th March, 2021 30/March/2021 Amends NN 89/2020 and extends penalty free period for non-compliance of QR on B2C,Upto 30/Jun/2021 Waives penalty u/s 125 CGST Act (Rs.25,000) for non-compliance of QR code printing on B2C invoices, until 30/June/2021, Provided that the qualified person complies with the provisions of the said notification from the 31st day of July, 2021

Q. 1 What is the Rationale behind B2C Dynamic QR codes?

Ans. It seems that the rationale for QR on B2C was to curb illegal suppression of B2C transactions now, as B2B invoicing had already seemingly been controlled vide E-way bills and IRN numbers.

But a retail customer may not always opt for the displayed Dynamic QR, and is free to use other Static modes for making payment.

He may even skip everything and make a cash payment, without bothering for either the Dynamic or the Static QR’s made available to him by the retailer.

Question then remains as to how a mere “cross reference of the mode of payment” on the retail B2C invoice solve the quandary of suppression of sales? As the retailer is again free to suppress his cash sales and might destroy the cashed invoice after the customer leaves. So the issue remains unchecked.

(N.B. – A circular no. 146/02/2021-GST dated 23/Feb/2021, was also issued to clarify the questions raised by several stakeholder regarding B2C invoice QR Codes)

Also, if the payment is made using the non-cash mode, there’s no need to build redundancy vide a QR, as the payment is made from a Bank to a Bank, which is already traceable.

QR on B2C invoices will not yield desired result until the customer is also entitled to an Input Tax Credit, howsoever little. Else this seems to be only a one-sided effort, with the other end reaching nowhere.

This needs further supplementing, which may already be on cards of the government!

Why should a Law be made always for the Law-breaker?! 

Disclaimer: The view above are author’s only and professional discretion is warranted before acting upon such advice/opinion. 

List of Notifications concerning B2C QR Code

1.  Notification No. 06/2021 – Central Tax Dated- 30th March, 2021

2. Notification No. 89/2020 – Central Tax  Dated- 29th November, 2020

3. Notification No. 71/2020 – Central Tax Dated 30th September, 2020

4. Notification No. 14/2020– Central Tax Dated21st March, 2020

5. Notification No. 72/2019 – Central Tax Dated 13th December, 2019

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