E invoicing Under GST

1. E INVOICING under GST –Latest
CA N.RAMASWAMY, F.C.A.
CHENNAI- 600024
PH- 04443512423
MOBILE: 9840446412
EMAIL: nryrams@gmail.com
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2. E INVOICE –An introduction.
• The GST Council approved the standard of e-invoice in its 37th Meeting
held on 20th Sept 2019and the same along with schema has been
published on the GST portal
• Notifications giving effect to the requirements of e-invoicing have been
issued on 13th Dec ’19. . As per the Notification No 70 /2019 CT a
registered person whose AGGREGATE TURNOVER IN A financial
year exceeds ₹ 100 crores would be required to generate e-invoices.
• The turnover criteria is to be seen at the PAN level which would also
include the supplies between the GSTINs having the same PAN (i.e. distinct
persons) and not at the registration or GSTIN level. If in the current
Financial Year the turnover exceeds the prescribed limit the provisions
will get attracted.
• Various time lines were set for trail Runs for Rs. 500.00 Cr turn over etc.
due to COVID -2019, the implementation gets delayed.
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3. E INVOICE –An introduction.
• What does generation of e-invoice require?
– It has been stated that the invoice generation interface would remain the
same for the assessees and they would not be required to generate any
invoices on the GST portal or any other portal.
– However, such generated invoices will have to be uploaded at the Invoice
Registration Portal (IRP) which will then generate the Invoice Reference
Number (IRN).
 When should the e-invoice be generated?
 The Specified Persons will have to generate the e-invoice before the
transportation of the goods. As per Rule 48(5), any invoice generated by the
Specified Persons without an IRN would be an invalid document which can
lead to denial of credit in the hands of the recipient. Hence, Specified Persons
issuing invoices even in cases where movement of goods are not involved will
have to generate e-invoices and print the relevant QR code obtained from the
IRP, on the invoices given to the recipients.
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4. E INVOICE –An introduction.
As per Rule 48(4) of the GST rule 2017, the Specified Persons would be required
to obtain an IRN by uploading information filled in Form GST INV-01. The
Common Goods and Services Tax Electronic Portal for the purpose of
preparation of the e-invoice would be the following
– www.einvoice1.gst.gov.in; www.einvoice2.gst.gov.in; www.einvoice3.gst.gov.in;
– www.einvoice4.gst.gov.in; www.einvoice5.gst.gov.in; www.einvoice6.gst.gov.in;
– www.einvoice7.gst.gov.in; www.einvoice8.gst.gov.in; www.einvoice9.gst.gov.in;
– www.einvoice10.gst.gov.in
 However, it has been mentioned that the accounting software vendors would enable this aspect by
way of an interface between the accounting software and the above referred portals and the
assessee will only have to click a button to get the IRN generated from the IRP. Thereby, the
generation of the IRN would be a faceless interface wherein the assessee will not know the process
of the generation but will be given with the desired output.
 Once the IRN is generated the invoice will be transmitted to the assessee with a QR code on it. This
can be printed as any invoice which can be signed and sent. Important aspect to note is that
generation of the IRN/ the QR code only means that the invoice has been reported in the GST portal
and does not mean any authentication or signing of the invoice
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5. E INVOICE –To whom Applicable.
• Update as on 23rd March 2020
– The implementation of e-invoicing and the QR code has been deferred to 1st October
2020.
– Exemption from e-Invoicing and QR code has been granted to sectors such as the
insurance, banking, financial institutions, NBFCs, GTA, and passenger transportation
service, etc
• Update as on 30th July 2020
– 1. A new refined format of e-invoice has been notified by CBIC adding 20 new fields and
removing 13 fields. Certain fields have undergone changes in character length as well.
– 2. e-Invoicing system shall apply to those taxpayers with annual turnover exceeding Rs 500
crore instead of Rs 100 crore.
– 3. Special Economic Zones (SEZ) units shall also be exempted from issuing e-invoices.
– In view of the current amendment to the rules , e invocing procedure will be effective from
1-10-2020 for assesees whose turnover in the financial Year.
• For Assesses whose turnover exceeds Rs.500 Cr e invoicing procedure will be
operational from 1.10.2020. This applies to all supplies by the specified persons
for supply of goods, services or both.
• Does not apply to SEZ and sectors as such as Insurance, Banking, Financial
institutions, Goods transport/ passenger Transport
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6. E INVOICE –Latest Notification.
• MINISTRY OF FINANCE
• (Department of Revenue)
• (CENTRAL BOARD OF INDIRECT TAXES AND CUSTOMS)
• NOTIFICATION No. 13/2020–Central Tax
• New Delhi, the 21st March, 2020
• G.S.R. 196(E).-In exercise of the powers conferred by sub-rule (4) of rule 48 of the Central Goods and
Services Tax Rules, 2017(hereinafter referred as said rules), the Government on the recommendations
of the Council, and in supersession of the notification of the Government of India in the Ministry of
Finance, Department of Revenue No. 70/2019 – Central Tax, dated the 13th December, 2019, published
in the Gazette of India, Extraordinary, Part II, Section 3, Sub-section (i) vide number G.S.R. 926 (E),
dated the 13th December, 2019, except as respects things done or omitted to be done before such
supersession, hereby notifies registered person, other than 1[a Special Economic Zone unit and] those
referred to in sub-rules (2), (3), (4) and (4A) of rule 54 of the said rules, whose aggregate turnover in a
financial year exceeds 2[five hundred crore rupees], as a class of registered person who shall prepare
invoice and other prescribed documents, 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.
• 2. This notification shall come into force from the 1st October, 2020.
• [F. No. 20/06/03/2020-GST]
• PRAMOD KUMAR, Director
• NOTES:-
• 1. Inserted vide NOTIFICATION No. 61/2020–Central Tax dated 30-07-2020
• 2. Substituted vide NOTIFICATION No. 61/2020–Central Tax dated 30-07-2020 before it was read as
"one hundred crore rupees"
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7. A few Important Aspects to remember.
• Functions of IRP: A quick glance
• Before diving into amendment and cancellation of an e-invoice, we need to be aware that
an e-invoice is created on the basis of a prescribed schema and a unique Invoice Reference
Number (IRN) is assigned to each such invoice using a hash generation algorithm. The
taxpayer can either generate the IRN or upload the invoice onto the IRP as it is and the IRP
would generate the IRN. In case the taxpayer generates the IRN, the IRP will have to
validate the same.
• The IRP is an entity responsible for authenticating e-invoices by checking whether the
invoice follows the prescribed schema and mandatory parameters, whether the IRN is
unique, etc. Hence the website of an IRP and that of the GST portal is separate. Once an
IRP validates an e-invoice, it forwards the details to the GST portal.
• Amendment and cancellation on the IRP
• IRPs will process each invoice one at a time. However, to ensure that this process is
not slowed down due to the burden on the servers, the IRP will have a very lean and
focused system. To achieve this, one of the measures that will be used is that the IRP
will not be required to store e-invoices for more than 24 hours.
• Therefore, an e-invoice can be cancelled on the IRP only within 24 hours. Further, the
whole of the invoice would have to be cancelled since partial cancellation is not
possible. Amendments to an e-invoice cannot be carried out on the IRP.
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8. A few Important Aspects to remember.
• Amendment and cancellation on the GST portal
• While cancellation on the IRP is allowed only within 24 hours, amendment and
cancellation of e-invoices are allowed on the GST portal as per the provisions of the
law. Which implies that amendments and cancellations would continue to be made
as per the current system, i.e., reporting in Form GSTR-1.
• There has been no change in the scope for amendment and cancellation of invoices
with the introduction of the e-invoicing system with the exception that e-invoices can
be cancelled within 24 hours on the IRP.
Conclusion
The E INVOICING procedure will be effective with effect from 1-10-2020 based on
notification No 61/2020dated 30-07-2020. Mandatory for assesses whose aggregate
turnover during the financial year exceeds Rs. 500.00 Cr.
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9. .
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• Happy Reading
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