Recently, the National Informatics Centre has issued Frequently Asked Questions (‘FAQs’) dated August 5, 2020 on E-Invoicing. We have herein covered the noteworthy points as follows:

1. Applicability of E-Invoicing requirement

Taxpayers can verify on E-Invoicing portal whether they are liable to generate E-Invoices or not. Taxpayers need to go to E-Invoicing portal and click on “Search” à “E-invoice Status of Taxpayer” to know status of E-Invoicing enablement.

NITYA Comments: E-Invoicing is applicable to registered person whose ‘aggregate turnover’ in preceding Financial Year (FY) exceeds ₹ 500 crores. The term ‘aggregate turnover’ is defined under GST law to includes all taxable supplies, exempt supplies, exports and inter-state supplies of person having same PAN on all India basis. Thus, for computing threshold of ₹ 500 crores, taxpayers need to include GST turnover of all States including stock transfer of goods, purchase return, cross-charge of common services, employee recoveries etc.

2. Other points

• Nature of supply i.e. Inter-State / Intra-State supply will be decided basis ‘State Code’ and ‘Place of Supply’.

• Document date for generation of E-Invoice can be same or previous date only.

• Document number cannot start with ‘0’, ‘/’ and ‘-’.

• All alphabets need to be in upper case. 

• E-Invoicing system will not accept B2C transactions. If continuously requested by taxpayer, access will be blocked.

• For issuing Debit / Credit Note, validation of original invoice and other value will not be done.

3. E-way Bill

• E-way Bill (‘EWB’) and IRN mapping table can be downloaded from E-Invoicing portal.

• IRN and EWB can be generated together. However, cancellation will be done in two steps – first EWB and then IRN.

• EWB cannot be generated against Debit / Credit Note (since no movement of goods will be done).

• The movement of goods in CKD / SKD form will be done under multiple delivery challans and single E-Invoice will be generated for full value. This E-Invoice will accompany all delivery challans.

Hope you find this an interesting read. Please feel free to share your comments / feedback on the same.

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