Since the inception of GST, cases of fake invoicing and tax evasions are reportedly increasing year on year. As per the records, there has been sharp increase in cases of fake invoicing from 5 cases involving fraudulent claim of ITC amounting to Rs 12.67/- crores in first year to 1620 cases and amount manifolded to Rs 11,251/- crores till last fiscal (18-19).

In order to curb fake invoicing, tax evasion and to promote the tax payer services (pre-population of ANX-1 & II and reducing reconciliation problems) in better way, a much needed E-Invoicing finally going to be implemented in the phased manner.

This article discusses about the concept of E-Invoicing, applicability, steps & other aspects

1. What is E-Invoicing under GST?

  • E-invoicing is a mechanism or system which has been developed with the objective
  • to authenticate the B2B transactions automatically by GSTN
  • for further use on common GST portal
  • It does not mean generation of invoice by any computer system or tax portal.
  • E-invoicing standards approved by GST council in its 37th meeting held on Sept,2019
  • Generation of E-Invoice will be the responsibility of taxpayers.

2. Are all taxpayers required to generate E-Invoice under GST?

  • No, E-invoice is to be prepared by following class of persons-
Aggregate Turnover of Supplier in a FY Applicability status Date of applicability
>500 crores Voluntary 1st January ,2020
>100 crores Voluntary 1st February,2020
>100 crores Mandatory 1st April,2020
>500 crores (for B2C transactions) (note) Mandatory 1st April,2020
  • Note- QR code is required to be generated for B2C transactions by those taxpayers.

3. What is the procedure for generating an E-Invoice under GST?

  • Steps involved for generation of E-invoice which are to be followed in sequence

1. Generation of invoice by taxpayer in its accounting or billing software

2. Creation of JSON file of the same to upload it on Invoice Registration Portal (IRP)

3. Generation of Invoice Reference Number (IRN) by the supplier (Optional Step)

4. Uploading the JSON file & IRN(if generated) of the invoice to IRP

5. Generation of IRN by IRP(if not generated by the supplier) and its validation by IRP by digitally signing and attaching QR code after performing duplication checks

6. Once the invoice (JSON) is digitally signed by IRP & QR code is attached to it, it becomes an E- invoice and same will be sent to supplier & recipient by IRP on mail

7. The so called E-invoice can now be downloaded by both supplier and recipient

8. IRP transfer the details of E-invoice to invoice registry of GST and E-way Bill system

4. Is E-Invoicing applicable for all types of transactions?

  • At present, E-invoicing is applicable for B2B, Exports & SEZ sales.
  • Applicable for Tax invoices, Dr/Cr notes, RCM invoices except proforma invoices.

5. What is Invoice Reference Number (IRN)?

  • A unique number based on hash (logarithm of Supplier GSTIN, Invoice No., Type & FY)
  • Generated by IRP ,can also be generated by supplier but valid only once registered on portal
  • A Unique identity for each invoice for entire FY for a taxpayer
  • It is not a invoice number (invoice no. remain same as mentioned on the invoice)

6. What is Quick Response code (IRN)?

  • A code generated by IRP after validation of invoice (digital signing of invoice by IRP).
  • Consist of following E-invoice parameters-
    • GSTIN of Supplier& Recipient
    • Invoice Number, date and value (taxable & gross value)
    • No of line items, HSN code of main item ( highest taxable value), Unique IRN
  • Checking invoice by tax officer on roadside by offline app if internet not available.

7. What if e-invoice is not prepared by the taxpayer to whom E-Invoicing is applicable?

  • Then the invoice issued by them shall not be treated as invoice under CGST Act.

8. Is there any requirement to issue e-invoice in triplicate and duplicate ?

  • No, taxpayers who are required to prepare e-invoice are not required to do so.

9. Where the requirement of E-invoicing specified in GST?

  • The schema or standard has been issued and the same is available on GSTN
  • The applicability has been made vide Notifications No.68/69/70/71/72-CT dated 13th Dec, 2019.

10. What are the timings of issuing an E-invoice?

  • Invoice shall be issued as per invoicing provisions laid in section-31 of CGST Act,2017
    • For Goods-On or before removal of goods
    • For Services-before or after provisioning of service but within 30/45 days

11. Where the taxpayer is required to register invoice or modes of getting the invoice registered?

  • Invoice is to be registered in Invoice Registration Portal (IRP) a portal for registering invoice.
  • Following portal designated as IRP which will be made operational for E-invoicing
    • www.einvoice1.gst.gov.in / einvoice2.gst.gov.in / www.einvoice3.gst.gov.in
    • einvoice4.gst.gov.in/www.einvoice5.gst.gov.in www.einvoice6.gst.gov.in
    • einvoice7.gst.gov.in / www.einvoice8.gst.gov.in/ www.einvoice9.gst.gov.in
    • www.einvoice10.gst.gov.in
  • Multiple modes like-API based, Mobile app based, Offline tool based and GSP based.

Notifications issued for implementation of provisions related to e-invoice and QR Code for a class of taxpayers:-

Title Notification No. Date
CBIC notifies class of registered person required to issue GST invoice having QR Code Notification No. 72/2019–Central Tax 13/12/2019
CBIC notifies rule 46 of CGST Rules, 2017 (Tax Invoice) wef 01.04.2020 Notification No. 71/2019–Central Tax 13/12/2019
CBIC notifies Class of registered person required to issue e-invoice under GST Notification No. 70/2019–Central Tax 13/12/2019
CBIC notifies common portal for e-invoice under GST Notification No. 69/2019–Central Tax 13/12/2019
CBIC amends Manner of Issuing Tax Invoice under GST Notification No. 68/2019–Central Tax 13/12/2019

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Qualification: CA in Practice
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Location: Delhi, New Delhi, IN
Member Since: 27 Dec 2019 | Total Posts: 4

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