Business with turnover of more than Rs 500 crore will issue ‘e-invoicing’ with a Quick Response (QR) code from April 1.

This among various other provisions is part of five notifications, issued by the Central Board of Indirect Taxes and Custom (CBIC) to bring in place ‘e-invoicing’ system. The new invoicing system has been made mandatory for businesses having turnover of Rs 100 crore or more from April 1.

‘E-invoicing’ is a system in which invoices are authenticated electronically by GSTN (GST Network, the IT backbone for new indirect system) for further use on the common GST portal. This system will prescribe an identification number will be issued against every invoice by the Invoice Registration Portal (IRP) to be managed by the GSTN. All invoice information will be transferred from this portal to both the GST portal and e-way bill portal in real-time. Therefore, it will eliminate the need for manual data entry while filing ANX-1 (Annexure 1, part of new return mechanism going to be implemented from April 1)/GST returns as well as generation of part-A of the e-way bills, as the information is passed directly by the IRP to GST portal.

B2C businesses

Notification number 72 says, “An invoice issued by a registered person, whose aggregate turnover in a financial year exceeds five hundred crore rupees, to an unregistered person (hereinafter referred to as B2C i.e. Business to Consumer invoice), shall have Quick Response (QR) code, provided that where such registered person makes a Dynamic Q code available to the recipient through a digital display, such B2C invoice issued by such registered person containing cross-reference of the payment using a Dynamic Quick Response QR code, shall be deemed to be having QR code.”

According to other notifications, taxpayers with turnover of more than Rs 100 crore in a year will be required to prepare invoice by including such particulars (as contained in FORM GST INV-01), after obtaining an Invoice Reference Number by uploading information contained therein on the specified Portal. Further, unless the specified taxpayers prepare the invoice in the prescribed manner, the invoice shall not be treated as an invoice.

GST portals

In order to facilitate preparation of e-invoices, CBIC has also notified ten Common Goods and Services Tax Electronic Portals - 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 , and www.einvoice10.gst.gov.in .

Commenting on the new system, Abhishek Jain, Tax Partner at EY said that an official notification for effectuating e-invoicing for a specified class of businesses further fosters the Government's intent of mandatorily implementing this by April next year. “Businesses would need to on priority execute an "as is" mapping in their current invoicing system vis-a-vis the new requirment and commence executing the requisite changes in IT processes to be ready for this new change," he said.

Chartered Accountant Pritam Mahure feels that GST has seen a stream of never-ending changes as after more than thirty months into GST, the Act, Rules, rates and even the systems are evolving. Thus, GST payers have expectations that before the new e-invoicing system go live, it should be ensured that appropriate testing should be carried out and GST portal is designed to make it robust.

“Further, it may be noted that for GST payers the GST processes, returns and systems are continuously changing and thus, the Government should give adequate time and make technical regarding e-invoicing available in the public domain and interact, well-in-advance, with the large taxpayers for feedback on the same, “ he advised

The GST Council, in its 35th meeting decided to implement the new system while standard was adopted during 37th meeting. The plan is that businesses having a turnover of Rs 500 crore or more would take up e-invoicing from January 1, 2020 on voluntary and trial basis while the businesses with turnover of Rs 100 crore or more would start e-invoicing on voluntary and trial basis from February 1, 2020. However, it will be mandatory for both the categories from April 1, 2020 while for businesses having turnover less than Rs 100 crore, it would remain voluntary and on trial basis from April 1.

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