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Extension of date for furnishing Annual Return and One time relaxation of E-Invoice Compliance vide Notification No. 69/2020 – Central Tax to 72/2020 – Central Tax dated 30-09-2020 and Exemption Notification No. 04/2020-Integrated Tax – Rate etc.

Sl. No Notification No Date Summary of Notification
1 69/2020 – Central Tax 30-09-2020 Extension of due date for furnishing Annual Return to 31st October, 2020
2 70/2020 – Central Tax 30-09-2020 Notification related to E-Invoice

a.  The words “a financial year” has been substituted with “any preceding financial year from 2017-18 onwards”

b. After the word “goods or services or both to a registered person”, the word “or for exports” shall be added.

TaxMarvel Comments – The change is to bring clarity in the provisions of implementation of E-invoice provisions. Now, turnover criteria for e-invoice shall be reckoned where turnover has crossed in any preceding FY from 2017-18.

3 71/2020 – Central Tax 30-09-2020 Notification related to requirement of QR Code on B2C Invoices

a.  The words “a financial year” has been substituted with “any preceding financial year from 2017-18 onwards”

b. The implementation date has been deferred from 1st day of October, 2020 to 1st December,2020

4 72/2020 – Central Tax 30-09-2020 Changes in CGST Rules, 2017 – Following rules are amended –

Rule 46 (r) – Quick Reference code, having embedded Invoice Reference Number (IRN) in it, in case invoice has been issued in the manner prescribed under sub-rule (4) of rule 48.

Rule 48 – “Provided that the Commissioner may, on the recommendations of the Council, by notification, exempt a person or a class of registered persons from issuance of invoice under this sub-rule for a specified period, subject to such conditions and restrictions as may be specified in the said notification.”

Rule 138A – “(2) In case, invoice is issued in the manner prescribed under sub-rule (4) of rule 48, the Quick Reference (QR) code having an embedded Invoice Reference Number (IRN) in it, may be produced electronically, for verification by the proper officer in lieu of the physical copy of such tax invoice.”

5 04/2020-Integrated Tax – Rate

04/2020 – Central Tax (Rate)

04/2020-Union Territory Tax (Rate)

30-09-2020 Extension of IGST/UTGST/CGST exemption on services by way of transportation of goods by air or by sea from customs station of clearance in India to a place outside India, by one year i.e. upto 30th September, 2020

Press Release by CBIC on relaxation for invoices generated during October, 2020 

CBIC by issuing a press release has clarified on implementation on Electronic Invoice (E-invoice). Below are the highlights of the release –

  • Being in the initial phase of implementation, additional time of 30 days for generation of Invoice Reference Number (IRN) for invoices generated in the month of October 2020.
  • Invoices issued by taxpayers during the month of October 2020 shall be valid even if they do not comply with provisions of Rule 48(4) of the CGST Rules, 2017, if the Invoice Reference Number (IRN) is generated from Invoice Reference Portal (IRP) within 30 days from date of invoice.
  • No penalty shall be levied u/s 122 of the CGST Act, 2017 for delay in generation of IRN from invoice Reference Portal (IRP) provided they are generated within 30 days from issuance of invoice.

Example –

Invoice Date Generation of IRN Time Gap Remarks
3rd October 20 2nd November 20 Within 30 days In compliance with provisions and no penalty imposable
3rd October 20 5th November 20 Beyond 30 days Not in compliance with provisions and penalty imposable u/s 122
1st November 20 3rd November 20 2 days No relaxation for invoice generated post October 2020, hence, not in compliance with provisions and penalty imposable u/s 122

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Disclaimer: The content of this document is for general information purpose only. TaxMarvel shall not accept any liability for any decision taken based on the advice. You should carefully study the situation before taking any decision.

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