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On 1st August,2022,CBIC has issued  Notification No.17/2022-Central Tax-dated.01.08.2022, in exercise of the powers conferred by sub-rule (4) of rule 46 of the CGST Rules,2017, as per amendment that with effect from 1st day of October,2022, any registered taxable person with aggregate turnover exceeding Rs.10 Crores in any financial year 2017 -18, onwards by including such particulars contained in Form GST INV-01 after obtaining an Invoice Reference Number by uploading information contained therein on the Common GST Electronic Portal in such manner and subject to such conditions and restrictions as may be specified in the notification. Here with I am providing Important FAQ on an E-Invoice under CGST Act,2017, w.e.f.1st Aug’2022, to clear your doubts on the above subject.

What is an E-Invoice under GST Law,2017?

> E-Invoice means a taxable person supply of goods or / services to the recipient and want to raise an invoice for that supply of goods or / services, they can raise the digital invoice for goods and services provided. The taxable person can generate at the Government Common Portal of GSTN. E- Invoice is a standard format of the invoice recommended by GSTN for the GST registered persons under GST Law,2017.

Is it mandatory to use software of GSTN to generate E-Invoice at Common Portal?

> The tax payer would continue to use their existing accounting system/ERP or excel based tool for generating the E-Invoice. The taxpayer can use his existing software to generate the new E-Invoice standard wherein they would realign their data access a retrieval in the standard format.

Is any standard format of E-Invoice format is  prescribed by the CBIC or GSTN?

> Yes, As per Rule 48(4) of CGST Rules,2017, the E-Invoice shall be prepared by such class of registered persons as may be notified by the Government by including such particulars contained in FORM GST INV.01 after obtaining an Invoice Reference Number by uploading information contained therein on the Common Portal of GSTN.

> As per Rule 48(5) of CGST Rules,2017,”Every E-Invoice issued by a person to whom sub-rule (4) applies in any manner other than the manner prescribed in the said sub-rule shall not be treated as an Valid E-Invoice.

Is it necessary to take registration for generate E-Invoice with Invoice Registration Portal (IRP) of the GSTN Common Portal?

> Yes, If the taxable person wants to generate E-Invoice through Common Portal or his existing software or existing accounting system, he shall take registration with the GSTN at Invoice Registration Portal otherwise such E-Invoice will be considered as an invalid invoice and Input Tax Credit (ITC) is not available to the recipient on such invalid E-Invoice.

Is it mandatory to generate E-Invoice by every registered taxable person under GST Law?

> No, As per Notification No.17/2022-Central Tax,dated.01.08. The Government exercised the power conferred by rule 48(4)  and notified registered person, whose aggregate turnover in a financial year 2017-18 onwards exceeds Rs.10 Crores.

Sr.No. Notification No. & Date Aggregate Turnover Effect from
1. 13/2020 dated.21st March’2020 and 61/2020 dated.30th July,,2020 Exceeding Rs.500 Cr. 1st Oct’2020
2. 88/2020 dated.10th November,2020 Exceeding Rs.100 Cr. 1st Jan’2021
3. 05/2021 dated.8th Mar’2021 Exceeding Rs.50 Cr. 1st Apr’2021
4. 01/2022 dated.24th Feb,2022 Exceeding Rs.20 Cr. 1st April,2022
5. 17/2022 dated.01st Aug,2022 Exceeding Rs.10 Cr. 1st Oct,2022

> For the purpose of calculation of aggregate turnover has been defined under Sec.2(6) of CGST Act,2017. The taxpayer needs to upload invoices in Invoice Registration Portal (IRP), in case the aggregate of all GSTNs based on the same PAN is more than Rs.10 Cr. in a Financial year 2019-20.

Is any facility provided by the GSTN for verification of E-Invoice by the Recipient under E-Invoice System at Common Portal?

> Yes, The GSTN has developed portal of E-Invoice, which provides facility /an App to the recipient or any third person to check the correctness/ validity of such E-Invoice issued by the supplier to them. Anyone can verify the authenticity or the correctness of E-Invoice by uploading the signed JSON file or Signed QR ( Quick Reference) Code into the e-invoice system.

> The option Verify Signed Invoice under the search option can be selected and the signed JSON file can be uploaded and verified. Similarly the QR(Quick Reference) Code Verify app may be downloaded and used to verify the QR(Quick reference ) Code printed on the E-Invoice.

Is  there any exemption for any specific class of persons from generating  E-Invoice under GST Law,2017?

> Yes, The Government has given relaxation to certain class of persons from generation of E-Invoice under GST Law,2017. As per N.No.13/2020-Central tax, Dated.21st march,2020 has been issued under Rule 48(4) in supersession of the N.No.70/2020-Cnetral Tax-dated.13.12.2019, which gives an exemption from the generation of E-Invoice to these following specific class of persons:

(i) An insurance Company, Banking Company, or Financial Institution including NBFC,

(ii) Goods Transport Agency (GTA),

(iii) Passenger Transport Service,

(iv) Admission to the exhibition of Cinematograph Films in Multiplex Screens.

(v) Special Economic Zone Units but not SEZ Developers (SEZ developers are not exempted from issue E-Invoice) as per N.No.61/2020- Central Tax-Dated.30th July, 2020.

If the above specified exempted taxable persons are having multiple business units, such multiple business units are also exempted from generation of  E-Invoices under GST Law,2017?

> No, If the above specific exempted taxable persons are having multiple business units within the same GSTIN, we have to verify and ascertain the activities of such multiple business units, which are not covered within the above mentioned exemptions. Ex: If a Goods Transport Agency (GTA ) is having commercial Immovable property( Godown) and such services and his aggregate turnover exceeds more than Rs.500 Crores , such person is not exempted for issuing E-Invoice. In my opinion, If the above specified person are having other business activities along with the above mentioned exempted activates are not permitted to get exemptions from generating E-Invoices.

Can anyone generate E-Invoice through Common Portal of GSTN?

> No, Supplier only can generate E-Invoice. Others cannot generate E-Invoice like Recipient or Transporter through Common Portal of GSTN. In the case of RCM also Supplier can generate E-Invoice but RCM tax liability under RCM discharged by Recipient only.

> Further, If the taxpayer is having aggregate turnover more than Rs.500 Cr, such taxpayer cannot issue E-Invoice to B2C supplies. If taxpayer can generate E-Invoice continuously, the access of generation of E-Invoice system through Common portal will be blocked.

> Further , if the taxpayer issuing E-Invoice to supply of taxable and exempted supply of goods / or services under single invoice would be difficult, so, he will be required to issue E-Invoice in respect of taxable supplies only. He cannot issue E-Invoice to exempted supply under the system of E-Invoice. He can generate E-Invoice under his existing system/existing accounting system only.

Is any specific mechanism for generation of E-Invoice under GST Law,2017?

> The tax payer can use his existing software or existing accounting system / ERP or Excel based tool for generating the E-Invoice. Existing software would adopt the new E-Invoice standard format wherein he will be re-align their data access and retrieval in the standard format (schema) that is published on the GST Portal and have the mandatory parameters. The tax payer can choose optional parameters as per his business need.

> It is mandatory to know the accuracy and the  preparation of E-Invoice. It is important to educate the accountant or the person who are entering the details in the ERP system, The firm should make sure that the person who generates E-Invoice in ERP is trained and understand the contents to be entered in the ERP system.

Is there any models for generating E-Invoice under GST Law,2017?

> Yes. Multiple modeswill be made available for getting eInvoices registered on the Invoice Registration Portal (IRP). Some of the proposed modes are- The ways to get einvoice registered on the Invoice Registration Portal (IRP) are: Website, API, SMS, Mobile app, Offline tool and GST Suvidha Provider (GSP).

> Further, the taxpayer can generate E-Invoice in Offline Facility. i.e. bulk upload tool. In this system , the taxpayer prepare and upload the file containing the multiple IRN requests and the E-Invoicing system will process each one of them and return the IRN for all as applicable.

> Further, the tax payer can generate by way of direct API system. This is a direct method of taxpayer system requesting for IRN and E-Invoicing system will return the IRN.

Further, if the taxpayer want to choose API integration through GSSP system: Under this system ,the taxpayer system will direct the request for IRN through GSP and the E-Invoicing system will return IRN. ERP shortlisted by GSTN to work as GSP and E-Commerce Operator has been enabled to register and test the APIs on the sandbox system. The taxpayer can appoint more than one GSPs also for availing E-Invoice .

> In the case of E-Commerce transactions, the E-Commerce Operator can request for the IRN/E-Invoice on behalf of the supplier. In this case the E-Commerce Operator should have been registered on the GST Portal under E-Commerce Operator category and use e—c Com GSTIN accordingly.

Is any specific format prescribed for E-Invoice under GST Law,2017?

> Yes, The GST Council approved the standard format of E-Invoice in it’s 37th Meeting held on 20th Sept,2019 and the same along with SCHEMA has been published on the GST Portal. E-Invoice format for electronic invoices. It is termed as GST-INV-1. The same E-Invoice schema will be used by all kinds of taxpayers and no separate format is required for different kinds of users like Traders, Medical Business units, Professionals and Contractors etc.,

> The government has issued notification No.60/2020-CT-dated 30.07.2020 on format of schema about mandatory and optional fields of E-Schema. The schema is having two fields, they are mandatory fields and non-mandatory fields. A mandatory field has to fill up by all the taxpayers and the non-mandatory fields are optional for the business to choose from. Specific types of business may choose to use those non-mandatory fields which are required by them or their business convenient.

E-Invoice under GST as per Notification No.17-2022-C.T. dt. 01.08.2022

What is Invoice Reference Number (IRN) under GST Law,2017?

> Invoice Reference Number is a number allotted by the government to tag and identify valid E-Invoice generated through Invoice Reference Portal (IRP). The supplier uploads the JSON of the invoice into the Invoice Reference Portal (IRP) once, the portal will generate the shuffle. The shuffle generated by Invoice Reference Portal (IRP) will become the Invoice Reference Number) of the E-Invoice. This shall be unique to each invoice and hence be unique identity for each invoice for the entire financial year in the entire GST system for a taxpayer.

Key features of Invoice Reference Number:

(i) It is a unique 64 characters shuffle based on 4 parameters which are supplier GSTIN+ Fin. Year+ Doc Type+ Doc number,

(ii) Invoice Reference Number (IRN) is different from invoice number,

(iii) Invoice Reference Number (IRN) required to be generated before the issuance of the invoice or before the movement of the goods,

(iv) Invoice Reference Number generated remains on the Invoice Reference Portal (IRP) portal for 1 or 2 days.

(v) Invoice Reference Number generated by the Invoice Reference Portal (IRP) portal is stored in the GST Invoice Registry under GST systems.

How to validation of E-Invoice by the GSTN Common Portal ?

> The taxpayer has to upload the complete invoice details, prepared manually or through an internal ERP / Existing accounting system, as per the prescribed format only after due validation of the data. Recipient GSTIN should be registered and active. The business needs to ensure valid GSTIN of the recipient in their system.

> In the case of direct export, the recipient GSTIN has to be Unregistered Person (URP) and State Code has to be 96, PIN code should be 999999, Place of Supply (POS) should be 96. HSN/SAC Code should be validated as per GST Master Codes. Financial year will be derived based on the document data. Unique series of the invoice should be maintained throughout the financial year.

> The passed value should be between the minimum and maximum values as explained here. The minimum value is considered as the rupee part of the calculated value minus one rupee and the maximum value is taken as the rounded up to next rupee value of the calculated value plus one rupee. In the case of Credit and Debit notes the tax rate can be passed with any value. In the case of passing IGST value of item will not be validated even actual tax rate is passed in case of Export without payment (EXPWOP) and SEZ without payment (SEZWOP). If the passed value of IGST for that is ZERO.

How to Validation of Invoice Reference Number (IRN) ?

> If the Invoice Reference Number is already generated on a particular type of document and document number of the supplier for the financial year, then one more Invoice Reference Number (IRN) cannot be generated on the same combination. Maximum number of items in each invoice should not exceed more than 1000line items and a minimum of 1(One) line item should be available. If any taxpayer is required to report more than 1000 line items may contact NIC (National Informatics Center).

> Document number should not be starting with 0 , / and -.If so, then the request is rejected. In the case of Reverse Charge transactions, The taxpayer can be set as “Y” in case of B2B invoices only and tax is being paid in a reverse manner as per rule. Even in the case of RCM invoices (Reverse Charged Invoices) the supplier has to generate the Invoice Reference Number (IRN). So, in the case of RCM invoices ,supplier can generate E-Invoices but Tax discharged on RCM Invoices by Recipient only.

> In case of any error invalidation, the error code and its details can be referred from https://einv-apisandbox.nic.in/api-error-codes-list

Is it possible to amend an E-Invoice by supplier under E-Invoice System of GSTN?

> If the supplier want to amend any E-Invoice, he can amend such E-Invoice will be done on the GST Portal only. JSON sent for the generation of E-Invoice cannot be amended. Invoice Reference Number (IRN) cannot be amended. So, the supplier can amend E-Invoice only before send JSON file to GST Portal for generation Invoice Reference Number (IRN) otherwise he cannot amend.

Is it possible to cancel an E-Invoice by supplier under E- Invoice System of GSTN?

> Yes, subject to certain conditions. E-Invoices mechanism enables invoices to be cancelled. This will have to be reported to Invoice Registration Portal (IRP) within 24 hours. Data on Invoice Registered Portal (IRP) will be kept there only 24 hours only. Any cancellation after 24 hours could not be possible on Invoice Registration Portal (IRP). But the supplier can manually cancel the same on the GST Portal before filling returns.

> E-Invoice cannot be partially cancelled. It cannot be cancelled if a valid e-waybill exists for that Invoice Reference Number (IRN) as goods are in movement. Amended invoice cannot be cancelled ( even within 24 hours) and will be kept for audit trail. Invoice Reference Number (IRN) cannot be generated again on the same invoice number. Invoice Reference Number (IRN) cannot be re-generated for the cancelled invoice. Fresh invoice required to be raised for generating Invoice Reference Number (IRN).

How to take printout of E-Invoice under E-Invoice system of GST ?

> The taxpayer can take print out on his paper invoice as he is doing today including LOGO and other information of the tax payer company. Regarding printing of LOGO, software company has to provide a place holder for company LOGO in the billing/ accounting software , so that it can be printed on the supplier’s invoice using his printer. The Company’s LOGO will not be part of the JSON file to be uploaded on the Invoice Registration Portal (IRP). The place holder is not provided in the E-Invoice schema for the company logo.

> Further, E-Invoice will be digitally signed by the Invoice Registration Portal (IRP) after it has been validated. The signed E-Invoice along with Quick Response (QR) Code will be shared with the creator of the document as well as the recipient. If the taxable person wants to sign manually on E-Invoice can do after taking printout.

What is the meaning of Quick Response (QR) Code under E-Invoice System?

> Quick Response Code (QR) code means it is part of the JSON file returned by Invoice Registration Portal (IRP). It is mandatory to print the Quick Response (QR) on the invoice. It can be printed anywhere on the E-Invoice. The size of the printed signed Quick Response (QR) Code can be 2X2 inches. Further, it is depend upon size of the space available on the invoice. But is should be readable from the Quick Response (QR) Code scanners. Printing of Quick Response Code on separate paper is not allowed. The tax payer can print more than 1 QR Code on the E-Invoice at proper annotation is required.

What are the contents of Quick Response (QR) Code of E-Invoice System of GST?

> The contents of Quick Response (QR) Code are (i) Supplier’s GSTN, (ii). Recipient’s GSTN, (iii) Invoice number as given by supplier , (iv) E-Invoice Generation Date, (v) Invoice value ( Taxable value and Gross Tax component). (vi) No. of line items, (vii) HSN Code of the main item ( Line item having the highest taxable value) (viii) Unique Invoice Reference Number (UIRN).

Is the credentials of E-Way Bill system will work on E-Invoice System of GST?

> The Invoice Registration Portal (IRP) will be share the signed E-Invoice data along with Invoice Registration Number (IRN) itself or by using the Invoice Registration Number (IRN) as a reference or by calling E-Way Bill API is separately.

> The system of E-Way Bill generation can be generated only Part A of the E-Way Bill. The remaining operation of E-Way Bills can be performed on the E-Way Bill System.

E-Way Bill system will create details of Part-A of E-Way Bill using this data to which only vehicle number will have to be attached in Part-B of the E-Way Bill. In spite of that, for the transportation of goods carrying an E-Way Bill will during transport of goods will continue to be mandatory.

> Kindly note that even the E-Way Bill system directly integrated with the E-Invoicing system and therefore, it is totally upon the choice of the taxpayer, if they want to generate E-Way Bill at the time of generation of E-Invoice only to avoid additional time or duplication work. In spite of that , it is significant to note that E-Way Bill will not be generated ,if the supplier or Recipient GSTN is blocked due to non-filling of GST returns.

> E-Way Bill can also be generated from the same JSON file sent for registration at Invoice Registration Portal (IRP) . In spite of that the challenge would be in the issuance of E-Way Bill in case of delivery in installments. Invoice Registration Number (IRN) has to be generated before the E-Way Bill. The cancellation of E Way Bill is integrated with E-Invoice to enable the cancellation of E-Invoice.

What is the procedure to be followed for export of goods to generate of E-Invoice and E way Bill under  E- Invoice system of GST?

> In the case of export transactions for goods, if an e-way bill is required along with Invoice Reference Number (IRN) then the “Ship-To” addresses should be of the place / port in India from where the goods are being exported. Otherwise, the E-Way Bill can be generated later based on Invoice Reference Number (IRN) by passing the “Ship-To” addresses as the place/ port address of India from where the goods are being exported. The said functionality has been developed and released on 7th September,2020. I.e. Generate E-Way Bill by Invoice Registration Number (IRN) has been developed to enable the generation of E-Way Bill in case of export by passing the address of the port from where it is getting exported later.

Can taxpayer generate E-Way Bill for generation document types of Credit and Debit Notes services?

  • The taxpayer cannot generate E-Way Bill for document types of Credit and Debit Notes for services. PIN Code of Recipient GSTIN is mandatory, if Ship-To details are not entered. In case of incomplete information has been passed for generation of E-Way Bill, then Invoice Reference Number will be generated and returned but not E-Way Bill number. In spite of that, subsequently, based on Invoice Reference Number, E-Way Bill can be generated.

Where the taxpayer login for generation of E-Invoice under E-Invoice system of GSTN Common Portal?

> The taxpayer can use the below link for login to generate E-Invoice under E-Invoice System under GST Common Portal. If the tax payer has registered in the E-Way Bill Portal at https://ewaybillgst.gov.in , he can use the login credential i.e. username and password of the E-Way Bill system to login to the E-Invoice Portal, he is not registered in the E-Way Bill Portal, then he can register in the E-Invoice Portal at option Registration. The system enables him automatically for both the E-Way Bill and E-Invoice Systems.

Is there any option available to the taxpayer to know his eligibility for generation of Invoice Reference Number (IRN) at the E-Invoice System of GST Portal?

  • Yes, The taxpayer can come to know his eligibility for generation Invoice Reference Number (IRN) by going to the E-Invoice Portal and choosing the option of “E-Invoice status of Tax Payer” under the search option. On entry of the GSTIN of supplier, the system will indicate whether this GSTIN is enabled or notified for the Invoice Reference Number generation. One can upload the Invoice Reference Number (IRN) generated and signed the invoice file and et it verified on the portal for the authenticity of the Invoice Reference Number (IRN). For this option, the tax payer select “ Verify Signed Invoice” under the search option.

If the tax payer can use to generate E-Way Bill with use of API system, what is the procedure can followed?

> If the taxpayer can use API system to generate API System, E-Invoice API has two sets of credentials. (i) Client ID, (ii) Client Secret user I.D. and password for taxpayers with GSTIN . If the taxpayer is enabled to access the API directly, then they will get client ID, Client Secret user i.d password that can be used PAN India for all sister concerned GSTIN’s with the same PAN.

Is my E-Invoice generated securely under E-Invoice system at Common Portal of GSTN?

> Yes, it is very much secure as the portal is using HASH SHA 256.

Can taxpayer issue an E-Invoice on a future date?

> The date of the tax invoice should be the date on which it is being submitted or the date before the date on which it is being submitted.

The taxpayer wants to generate E-Invoice, How many digits of HSN codes should be shown on the E-Invoice?

> The taxpayer wants to generate E-Invoice, he can use minimum 4 digits of HSN code are to be shown in case of goods and services. Maximum 8 digits in the case of goods and in the case of services 6 digits.

Can supplier generate E-Invoice for supply  of goods and services or both to the Central Government, State Government or Local Authority or Government Department?

> If Government Departments is registered under GST-E-Invoice is applicable.

> IF government Departments is not registered under GST- E-Invoice is not required.

Disclaimer: The contents of this article have been prepared on the basis of Notification NO.17/2022-Central Tax. date d0 1st August,2022, issued by the CBIC. Although care has been taken to ensure the accuracy, completeness and reliability of the information available, the author assumes no liability.  Therefore, users of this information are expected to refer the relevant law, the information as given in no case shall be constructed as a professional advice or opinion.


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One Comment

  1. Nikita says:

    Do i have to put my September 2022 data in e-invoice format as it is applicable from 1st of october or i have to start from my october data. Please give solution.

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