S. No.

Issue

Clarification

1

Applicability of Dynamic QR Code on export invoices

Since E-Invoice is issued for exports treating it as B2B supplies, Dynamic QR Code is not needed.

2

Details to be captured in QR Code

Dynamic QR Code should contain following information:

–              Supplier GSTIN;

–              Supplier UPI ID;

–              Payee’s Bank Account number and IFSC;

–              Invoice number and date; and

–              GST amount (breakup of CGST, SGST, IGST, Cess)

Further, Dynamic QR Code should be in such form that it can be scanned to make digital payment.

NITYA Comments: There was no clarity on contents of Dynamic QR Code till now. This clarification will enable taxpayers to modify their IT systems to generate and print QR Code on invoices. Notably, these contents have not been prescribed in Rules or Notification and to that extent, Circular lacks force of law. Requirement of Supplier GSTIN, Invoice No., Invoice Date and breakup of GST payable was logically not needed in Dynamic QR Code.

3

Where customer opts to pay without using Dynamic QR Code (even after being given option), whether QR Code needs to be printed?

Suppliers making B2C supplies, will have following options:

Case 1: Payment is made before issuance of invoice – Where customer pays using any mode (UPI / Credit or Debit Card / Online Banking / Cash) with or without using Dynamic QR Code, supplier will need to provide details of such payment  (such as Transaction Id, Date, Time, Amount and Mode of Payment) on invoice. If cross-reference of payment is provided on invoice, it shall be sufficient compliance.

Case 2: Payment is made after generation / issuance of invoice – Supplier need to print Dynamic QR Code on invoice.

NITYA Comments: Notably, Notification No. 14/2020 – Central Tax dated March 21, 2020 exempts printing of Dynamic QR Code if recipient makes payment using Dynamic QR Code whose cross-reference has been mentioned on invoice. On the other hand, Circular moved beyond the scope of law by extending this relaxation to cases where customer makes payment through any mode, and its cross reference has been provided in invoice.

4

Where Dynamic QR Code is not displayed but supplier makes electronic mode of payment available to customer, will it be compliant of law?

5

Whether generation / printing of Dynamic QR Code is mandatory for prepaid B2C invoices?

6

Where E-Commerce Operators (‘ECO’) comply with Dynamic QR Code requirement, whether suppliers are also required to comply with the same?

If suppliers give cross reference of payment on invoice (pre-paid transactions), it shall be sufficient compliance.

Where payment is made after generation / issuance of invoice, supplier need to provide Dynamic QR Code on invoice.

NITYA Comments: For transactions through ECO, payment is collected by ECOs and not by suppliers. Hence logically, UPI details of ECOs should be provided. Since ECOs mandate printing of invoice through their IT systems, they will need to gear for this change.