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GST Update on E-invoicing by CBIC & GSTIN

As you may be aware, certain set of taxpayers (having aggregate turnover exceeding INR 500Crores) had started e-invoicing from 1st October, 2020. In the month of October, 2020, about 4.95 Crore invoices were generated by 27400 GSTINs.

In addition to the above, Government of India has now clarified that effective January 01, 2021 GST e-invoicing is mandated for all the taxpayers with aggregate turnover exceeding Rs. 100 Cr (in any preceding financial year from 2017-18 onwards).

In this regard, the Central Board of Indirect Taxes (CBIC) and Goods and Services Tax Network (GSTN) have updated the following FAQs published on their website:

Q.11   Is e-invoicing applicable for NIL-rated or wholly-exempt supplies?

  • In those cases, a bill of supply is issued and not a tax invoice.

Q.12  Whether the financial/commercial credit notes also need to be reported to IRP?

  • No, only the credit and debit notes issued under Section 34 of CGST/SGST Act have to be reported.

Q.13  Whether e-invoicing is applicable for supplies by notified persons to Government Departments?

  • E-invoicing by notified persons is mandated for supply of goods or services or both to a registered person. Thus, where the Government Department doesn’t have any registration under GST (i.e. not a ‘registered person’), e-invoicing doesn’t arise.
  • However, where the Govt. department is having a GSTIN (as entity supplying goods/services/ deducting TDS), the same has to be mentioned as recipient GSTIN in the e-invoice.

Q.75   After obtaining signed JSON (along with IRN/QR Code) from e-invoice portal and while issuing invoice copy to the recipient, whether supplier’s signature / digital signature is required on invoice?

  • The requirement is governed by the provisions of Rule 46 of CGST Rules, 2017.

Enclosed are the updates issued by CBIC and GSTN on the above for your reference.

Trust the above update is useful.

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