Roadmap for e-Invoicing was laid down with approval of GST Council in its 37th meeting and issue of notification by the Government bearing number 68/2019 CT to 72/2019 CT in December 2019. Due to Global pandemic, implementation of e-Invoicing deferred from April 2020 to October 2020.

One of the myths among traders is that e-invoice will replace manual/own system generated invoice, but it is not the case. Traders will have to prepare/generate invoice manually/ in own system and upload the same on designated portal Invoice Registration Portal (“IRP”), which inter-alia will generate Invoice Reference Number (“IRN”) and quick response code (“QR Code”).

Businesses are required to generate an e-invoice for every sale transaction accounted/reported on their respective ERPs, thus creating an e-invoice is the prior responsibility of the taxpayer (dealer).

Currently threshold limit for generating e-invoice is under:

Threshold Limit Type of invoice to be issued as e-
invoice
Aggregate Turnover > 500 Crore All i.e. B2B + B2C
Aggregate Turnover between 100 Crore to  500 Crore (w.e.f.
01.01.2021)
B2B
Aggregate Turnover above 50 Crore (w.e.f. 01.04.2021) B2B

E-Invoice – Process Flow

Registered person can create e-invoice through GSP, third party software or Offline tool available. It will involve following steps:

> Preparation of invoices in own accounting software or manually;

> Using third party software or own accounting software (through purchased plugins) or offline utility, generate JSON file of all such invoices;

> Uploading of JSON file on IRP;

>  IRP will validate and approve the JSON file and will generate IRN, digitally signed e-invoice;

> IRN along with digitally signed e-invoice will be sent to registered person;

> IRN will also send such e-invoices to the buyer on their mail IDs as provided on the invoice;

> IRP will also generate QR Code for each invoice after uploading JSON of invoices along with IRN. The QR Code will consist of summarized information from the invoice.

The 39th GST council meeting came up with a decision to implement GST e-invoicing of bills and applicability of QR codes from 1st October 2020.

Summary of various notifications issued in this regard is as under:

Sr. No. Notification No. and Date Contents of Notification
1 68/2019 CT dated 13th Dec 2019
  • Obtain Invoice Reference Number (IRN) after furnishing required information on common portal.
  • Valid tax invoice means e – invoice only. Normal invoice prepared currently will not be considered as compliance of law.
2 69/2019 CT dated 13th Dec 2019
  • For the purpose of preparation of e-invoice 10 common portals as Invoice Registration Portal have been notified – www.einvoice1.gst.gov.in
3 70/2019 CT dated 13th Dec 2019
  • E invoice is applicable to registered person, whose aggregate turnover in a financial year exceeds INR 100 Crore.
  • Mandatory requirement of e-invoice for B2B transactions w.e.f. 01 October 2020.
4 71/2019 CT dated 13th Dec 2019
  • QR Code will be mandatory on tax invoice, from 1st April 2020, on supply to unregistered person (B2C).
5 72/2019 CT dated 13th Dec 2019
  • QR Code (Quick Response Code) is applicable to registered persons, whose aggregate turnover in a financial year exceeds INR 500 Crore, when such registered person issues Tax Invoice to an unregistered person [B2C].
6 13/2020 CT dated 21st Feb 2020
  • Exempts certain registered persons (Insurance Cos, Banks, NBFCs, GTA, Passenger transportation service etc) from e-invoicing implemented from 01 October 2020.
7 14/2020 CT dated 21st Feb 2020
  • Exempts certain registered persons (Insurance Cos, Banks, NBFCs, GTA, Passenger transportation service, OIDAR services etc) from mentioning Dynamic Quick Response (QR) Code implemented from 01 October 2020.
8 No.60/2020– CT dated 30th Jul 2020
  • Notifies new schema for e-Invoicing and content of Form GST INV-01 for e-Invocing applicable from 01 October 2020.
9 No.61/2020– CT dated 30th Jul 2020 (Amendment in Notification No. 13/2020 CT)
  • SEZ Unit brought within the ambit of e-invoicing.
  • Turnover limit increased from 100 Crore to 500 Crore for applicability of e-invoicing from 01 October 2020.
10 No.70/2020– CT dated 30th Sep 2020 (Amendment in Notification No. 13/2020 CT)
  • Definition of FY changed to FY 2017-18 onwards i.e. e-invoicing will be applicable in case turnover exceeds INR 100 Crore in any FY from FY 2017-18 onwards.
  • e-invoicing made mandatory for exports as well.
11 No.71/2020– CT dated 30th Sep 2020 (Amendment in Notification No. 14/2020 CT)
  • Definition of FY changed to FY 2017-18 onwards i.e. QR Code for B2C invoices will be applicable in case turnover exceeds INR 500 Crore in any FY from FY 2017-18 onwards.
  • Applicability of QR Code deferred from 01 October 2020 to 01 December 2020.
12 No.72/2020– CT dated 30th Sep 2020
  • Invoice having QR Code containing IRN will be considered a valid invoice and the same may be produced electronically, for verification by the proper officer in lieu of the physical copy of such tax invoice.
13 No.73/2020– CT dated 01st Oct 2020
  • Obtaining IRN for invoices issued without IRN during the period 01 October 2020 to 31 October 2020, within 30 days from the date of invoice by uploading details in FORM GST INV-01.
14 No.88/2020– CT dated 10th Nov 2020 (Amendment in Notification No. 13/2020 CT)
  • Applicability of e-invoicing extended to registered person having turnover of more than INR 100 crore in any FY from FY 2017-18 onwards w.e.f. 01 January 2021.
15 No.89/2020– CT dated 29th Nov 2020 (Amendment in Notification No. 14/2020 CT)
  • Waiver of general penalty of INR 25,000 for registered person liable to prepare e-invoice with dynamic QR Code for B2C supplies and have not prepared the same during the period Dec 20 to Mar 21, provided compliance is made good from 01.04.2021.
16 No.05/2021– CT dated 08th Mar 2021 (Amendment in Notification No. 13/2020 CT)
  • Applicability of e-invoicing extended to registered person having turnover of more than INR 50 crore in any FY from FY 2017-18 onwards w.e.f. 01 April 2021.

Other important aspects of e-Invoicing:

> Clarification in respect of applicability of Dynamic Quick Response (QR) Code on B2C invoices and compliance of Notification No. 14/2020 provided vide Circular no. 146/02/2021-GST dated 23rd February 2021.

According to said circular QR Code for B2C invoices should contain the following information:

i. Supplier GSTIN number

ii. Supplier UPI ID

iii. Payee’s Bank A/C number and IFSC

iv. Invoice number & invoice date,

v. Total Invoice Value and

vi. GST amount along with breakup i.e. CGST, SGST, IGST, CESS, etc.

Further, Dynamic QR Code should be such that it can be scanned to make a digital payment.

> Rule 46 of CGST Rules, 2017 as amended from time to time provides particulars and contents of valid Tax Invoice;

> Rule 48 of CGST Rules, 2017 provides for manner of issuing tax invoice i.e. Triplicate copies in case of goods and duplicate copies in case of services and various other aspects of e-invoicing;

> Rule 54 of CGST Rules, 2017 deals with non-applicability of e-invoicing provisions to certain class of registered person.

Author Bio

More Under Goods and Services Tax

3 Comments

  1. Mahesh Kr Sharma says:

    Thanks for nice presentation of notification in orderly manner. My question is, I will be liable to generate E invoices on and from 01-04-2021 as my turnover is >50.00 crore. For practice, Can I prepare E invoices prior to 1st april of my sales? Is there any adverse consequences if I do so?

  2. Vinod Daga says:

    Excellent work to sum up all the notification on single page.
    can u provide ur comments, that if we generate our excel Invoice(services invoice) on 31-03-2021 but generate the IRN on 10-04-2021 than what will be the consequences. whether it will be valid Invoice for FY 20 21, if not than what are the penalty.
    Thanx

    1. hiteshkothari says:

      Generating e-invoice is a prior responsibility or you can say it has to be on a real time basis as you need to mention IRN on your invoice while sending it to the client.

      In case generating an e-invoice is applicable to you with effect from 01.04.2021 then you are not liable to generate IRN for invoice prepared prior to said date.

Leave a Comment

Your email address will not be published. Required fields are marked *

Search Posts by Date

April 2021
M T W T F S S
 1234
567891011
12131415161718
19202122232425
2627282930