Top Ten FAQ’S About E-Invoice under GST

CBIC has recently issued various notifications to make compliance of E-invoice under GST regime mandatory for certain category of person from the specified date. The purpose of this article is to answer the top 10 question about the E-invoice as per rule 48(4) CGST Act and others respectively.

Q 1. What is E-Invoice under GST?

Ans: As per Rule 48(4), the invoice shall be prepared by including such particulars contained in FORM GST INV-01 after obtaining an Invoice Reference Number by uploading information contained therein on the Common Goods and Services Tax Electronic Portal in such manner and subject to such conditions and restrictions as may be specified in the notification.

E-invoice will be an invoice with the entire requirement as per rule 46 and will have invoice reference number generated from Common Goods and Services Tax Electronic Portal as per rule 48(4).

Q 2. What will happen if the notified category doesn’t generate E-Invoice or create an invoice without Invoice reference number generated from the portal?

Ans: As per Rule 48(5), every invoice issued by a person to whom sub-rule (4) applies in any manner other than the manner specified in the said sub-rule shall not be treated as an invoice. 

All the consequence of supply without generating invoice may apply like penalty under section 122(1), detention under section 129 etc.

Q 3. Which class of registered person is notified in terms of sub-rule (4) of rule 48 for the generation of E-Invoice?

Ans: The Government, on the recommendations of the Council, has notified registered person, whose aggregate turnover in a financial year exceeds one hundred crore rupees, as a class of registered person who shall prepare invoice in terms of sub-rule (4) of rule 48 of the said rules in respect of supply of goods or services or both to a registered person.

Q 4. Is E-invoice compulsory when supply is made to a receiver whose turnover is more than Rs? 100 crore?

Ans: E-invoice requirement is imposed on the supplier only when their aggregate turnover in a financial year exceeds the specified limit of Rs.100 crore.  If the supplier turnover is less that specified limit and the receiver turnover exceed the specified limit of Rs.100 Crore than E-invoice is not required, as the requirement is imposed based on the turnover of supplier not based on the turnover of the receiver.

Q 5. What is the effective date for implementation of sub-rule (4) of rule 48 for the generation of E-Invoice?

Ans: The effective date for implementation of sub-rule (4) of rule 48 for the generation of E-Invoice for the notified category shall come into force from the 1st day of April 2020. However, it is expected that compliance can be started on a voluntary basis from 1^st January 2020.

Q 6. What is the official website notified for the generation of E-Invoice?

Ans: As per notification no 69/2019 – Central Tax dated 13th December 2019, the Common Goods and Services Tax Electronic Portal for the purpose of preparation of the invoice in terms of sub-rule(4) of rule 48 of the aforesaid rules, namely:-

(i) www.einvoice1.gst.gov.in;

(ii) www.einvoice2.gst.gov.in;

(iii) www.einvoice3.gst.gov.in;

(iv) www.einvoice4.gst.gov.in;

(v) www.einvoice5.gst.gov.in;

(vi) www.einvoice6.gst.gov.in;

(vii) www.einvoice7.gst.gov.in;

(viii) www.einvoice8.gst.gov.in;

(ix) www.einvoice9.gst.gov.in;

(x) www.einvoice10.gst.gov.in.

This notification shall come into force with effect from the 1st day of January 2020. It gives an indication that the above website will be operational from 1^st January 2020, so that trial run and compliance on a voluntary basis can be started well before the compulsory timeline.

Q 7. What are the contents required to be uploaded in Common Goods and Services Tax Electronic Portal for generating E-Invoice?

Ans: For generating the invoice reference number the content as asked in the form GST INV-01 form need to be uploaded in the Common Goods and Services Tax Electronic Portal are as follows :

I. Details of Supplier (details which will be auto-populated)

GSTIN, Legal name, Trade name, Address

II. Date & Serial number of Invoice

III. Details of Supplier & Consignee

IV. Type of Supply

V. Details of Supply

VI. Authorisation or Signature

Signature, Name of the Signatory, Designation or Status

Q 8. Is furnishing of Quick Response (QR) Code mandatory in E-invoice?

Ans: A registered person whose aggregate turnover in a financial year exceeds Rs. 500 Crore shall issue an invoice containing Quick Response (QR) Code in case of supply made to unregistered person.

QR Code on B2C Invoices shall become mandatory from 01.04.2020

Q 9. How many copies of E-invoice need to be generated?

Ans: The invoice shall be prepared in triplicate as per rule 48(1), in the case of a supply of goods and in duplicate copy as per rule 48(2), in the case of a supply of services.

However, the rule 48(6) says that the provisions of sub-rules (1) and (2) shall not apply to an invoice prepared in the manner specified in sub-rule (4) i.e. to E-invoice.

Q 10. What time the E-invoice will be generated?

Ans: There will be no change in the timing of generation E-invoice; it will be same as per section 31. For goods the time of generation of invoice will be, before or at the time of removal of goods/delivery of goods etc. and for service before or after the provision of service within prescribed period as per section 31(2).

Disclaimers: The above FAQs have been prepared based on the prevailing law/provisions notification/circulars and clarification available as on date of publishing. There are personal interpretations involved in some of the situations which may vary. All possible efforts are made to make the above article error-free, however, if any error persists is purely unintentional and unintended. I welcome your feedback on the same. 

Links to the Notifications Related to E-invoice under GST

(CA Ramandeep Singh Bhatia, Practicing Chartered Accountant, Faculty –NACIN & ICAI , Raipur, [email protected])