Additional FAQs on E-Invoicing
Frequently Asked Questions (‘FAQs) dated August 5, 2020 released by the National Informatics Centre on E-Invoicing. Recently, new FAQs dated September 7, 2020 have been released on E-Invoicing. Some noteworthy points are as follows:
- In addition to mandatory particulars under Rule 46 of the Central Goods and Services Tax Rules, 2017, only QR code is required to be printed on invoice.
NITYA Comments: There was confusion since inception of E-Invoicing concept w.r.t. additional information to be printed on E-Invoice. Though this point is not specifically clarified in new FAQs, it comes as an inference. In one question, it is clarified that in addition to invoice being prepared by taxpayer (containing its logo, terms and conditions etc.), QR code only needs to be printed.
- ‘Taxable charges’ need to be reported through separate line item in each invoice. ‘Other charges’ can include any amount (like TCS) which does not form part of taxable value.
- QR code needs to be printed on invoice and not on separate paper. It must be readable on standard mobile devices.
- Printing of Dynamic Quick Response (‘DQR’) code on B2C invoices and E-Invoicing requirement for B2B supplies differ from each other.
NITYA Comments: From October 1, 2020, taxpayers having turnover of more than ₹ 500 crores (‘Notified supplier’) are required to undertake following compliances:
- Generation of E-Invoice for B2B supplies
- Generation of invoice with DQR code for B2C supplies. Alternatively, DQR code may be generated on POS machine
Both these requirements are mutually exclusive and not related to each other. Purpose of printing DQR code is to enable and encourage digital payments.
- Printing of IRN on invoice is optional and can be recorded by taxpayers in their ERP system for reference purpose. IRN is already embedded in QR code to be printed on invoice.
- Time limit of 24 hours to generate IRN is removed. Now, IRN can be generated before issuing invoice to customer or movement of goods.
- Generation of IRN is not required for self-invoice issued by recipient of reverse charge supplies.
- Taxpayers having turnover of more than ₹ 500 crores but showing status as “E-Invoice is NOT ENABLED for this taxpayer” can file self-declaration on portal to register themselves.
- E-commerce operators can generate E-Invoice on behalf of suppliers.
- Generation of IRN will be preceded by generation of e-way bill. Similarly, in case of cancellation, e-way bill needs to be cancelled first and then IRN.
- Government will also notify relaxation for requirement to obtain IRN in case of breakdown of internet connectivity in certain areas.
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