Reporting of TCS amount on Tax Invoice vis-à-vis E-way Bill and GSTR-1
This is to apprise you regarding practical issue emanated due to introduction of Tax Collected at Source (‘TCS’) under Income Tax law on sale of goods for reporting it on Tax Invoice vis-à-vis on E-way Bill and in GSTR-1.
Notably, there is no mandatory field for mentioning TCS on Tax Invoice (including E-Invoice). In FAQ’s issued by National Informatics Centre, it was clarified that taxpayer can mention TCS amount in the field of ‘Other Charges’ on E-Invoice. Accordingly, taxpayers started mentioning TCS amount on Tax Invoice.
Similar to Tax Invoice, E-way Bill and GSTR-1 do not have any field to report TCS amount.
NITYA Comments: Under Section 15 of the Central Goods and Services Tax Act, 2017, TCS is not includible in taxable value for computing GST. E-way Bill and GSTR-1 have fields of “Invoice Value”. However, “Invoice Value” is not defined under GST law.
Since Government has clarified that TCS amount should be included in ‘Others’ while generating E-Invoice, taxpayers can take similar call for E-way Bill and GSTR-1 as well. Hence, taxpayers can report TCS amount in ‘Other Charges’ on E-way Bill and ‘Total Invoice Value’ in GSTR-1. This will ensure that there is full matching of Invoice Value reported in different documents and forms (Tax Invoice, E-way Bill and GSTR-1).
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