Amendments in Central Goods & Services Tax Rules, 2017 regarding E-Invoicing

by | Oct 6, 2020 | Insight | 0 comments

Vide this email, we wish to appraise you regarding recent amendments in the Central Goods & Services Tax Rules, 2017 (‘CGST Rules’) and relaxation issued related to E-Invoicing. The gist of these amendments and our comments upon the same are tabulated as under:


NITYA Comments

Special procedure is notified for the month of October 2020. Taxpayers, who are required to generate E-Invoice, have an option to issue normal invoices and obtain Invoice Reference Number (‘IRN’) for such invoices within thirty days from date of such invoice. If IRN is not obtained within 30 days, invoices shall become invalid.


[Notification No.73/2020 dated October 1, 2020]


This is an added requirement for taxpayers and Government should have considered making this scheme optional for all taxpayers for 1 month. This would have given adequate time to industry to be ready.


The respective buyers will have to ensure that suppliers generate IRN within 30 days for validly availing ITC. Notably, the buyers will not be required to obtain amended invoice with QR Code for availing ITC since proviso to Rule 36(2) stipulates only few mandatory particulars (viz. tax charged, value of supply, GSTIN, Place of Supply etc.) for availing ITC. These particulars do not include IRN.

Quick Reference Code (‘QR Code’) has been made a mandatory particular on invoice.


[Notification No.72/2020-Central Tax dated September 30, 2020]


There was confusion since beginning regarding additional particulars required to be printed on E-Invoice. The mandatory requirement to print QR Code on invoice was clarified through recent FAQs and now has been made part of the CGST Rules.

E-Invoicing has been made applicable for exports.


[Notification No.70/2020-Central Tax dated September 30, 2020]


This point was also clarified through FAQs and has been given statutory recognition now. Notably, there is no legal provision which mandates issuing E-Invoice for debit notes and credit notes.

Production of electronic QR Code having embedded IRN is sufficient for verification of proper officer.


[Notification No.72/2020-Central Tax dated September 30, 2020]


E-Invoicing has been made mandatory for taxpayers having aggregate turnover of more than Rs.500 crores in any Financial Year (FY) from 2017-18


[Notification No.70/2020-Central Tax dated September 30, 2020]


Earlier, the Notification notifying taxpayers on whom E-Invoicing will be applicable was silent on FY for which turnover of Rs. 500 crores will be considered. Initial FAQs indicated that turnover of FY 2019-20 will be considered.


With revised criteria, E-Invoicing will be applicable to taxpayers who had turnover of more than Rs.500 crores in any FY from 2017-18.

Trust you find this an informative read! In case of any clarifications, please feel free to contact.



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