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What is eInvoice or eInvoicing system under GST?
An eInvoice under GST refers to any invoice generated through any accounting or billing software, which is reported and authenticated by the GSTN.
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What is IRN and IRP?
The invoice registration Portal (IRP) is the dedicated portal assigned by the GSTN for invoice reporting. In order to ensure authenticity, the IRP issues a unique Invoice Reference number (IRN).
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Is eInvoicing mandatory for all taxpayers?
No, only the taxpayer’s who have an aggregate turnover of INR 100cr or more need to generate an eInvoice.
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Will businesses now be required to generate e-invoices on the GST portal or eInvoice portal or the IRN portal?
No, Businesses will continue to generate e-invoices on their internal systems – whether ERP or their accounting / billing systems or any other application. The e-invoicing mechanism only specifies the invoice schema and standard so as to be inter-operable amongst all accounting/billing software and all businesses.
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Is the current e-invoice schema available for the invoice to be issued by Govt or it has to be maintained in the IT system by the tax payer?
The invoice schema has to be maintained and invoices generated using this schema by the taxpayer himself. The GST portal or Invoice Registration Portal (IRP) will NOT provide facility to generate invoices. IRP is only to report the invoice data.
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Will there be separate invoice formats required for Traders, Medical Shops, Professionals and Contractors?
No, same e-invoice schema will be used by all kinds of businesses. The schema has mandatory and non-mandatory fields. Mandatory field has to be filled by all taxpayers. Non-mandatory field is for the business to choose. It covers all most all business needs and specific sectors of business may choose to use the non-mandatory field as applicable for their business or the Business eco-system.
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How long will the e-invoice generated would be available at the Government portal?
The eInvoice shall be generated on the seller’s system, not on the government portal. However, once the eInvoice is validated and uploaded into the GST ANX-1 it will be visible to the counter party in his ANX. Thereafter it will be visible and available for the entire financial year and archived.
On the other hand, invoice data on IRP will be available for 24 hours only. -
While all businesses generate invoice at the same time, how will the server react?
The businesses will generate the invoice at their system and hence that will not impact the servers of IRP. The capacity of the system at IRP shall be built so as to handle the envisaged loads of simultaneous upload based on data reported in GSTR1 for last two years. Subsequently, multiple invoice registrars will be made available that will be able to distribute the load for invoice registration.
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Is it possible to auto populate fields of the e-invoice based on credentials entered? That way it can minimize data entry errors.
Since the invoice generation is to happen at the business end, this can be built into the ERP or invoicing system of the seller. Most of such software provides this facility in the name of item master, supplier master, buyer master etc.
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Will it be possible to add transporter details as well?
The transporter details can be entered in the E-Way bill system only.
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There are certain fields today which are optional and some mandatory. How are these to be used?
The mandatory fields are those that MUST be there for an invoice to be valid under e-Invoice Standard. The optional ones are those that may be needed for the specific business needs of the seller/business. These have been incorporated in the schema based on current business practices in India. The registration of an e-invoice will only be possible once it has ALL the mandatory fields uploaded into the Invoice registration Portal (IRP).
A mandatory field not having any value can be reported with NIL. -
What is the maximum Number of line items supported by e-invoice?
The maximum number of line items per eInvoice is 100.
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Does the e-invoice schema provide the maximum length of the various fields in the schema?
Yes, each field specification has been provided with the type of characters that are to be entered and its length as well.
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What will be the threshold requirement for E-Invoicing applicability?
This will be notified by the Government at the time of rollout.
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Will the e-invoice have columns to show invoice currency?
Yes, the seller can display the currency. Default currency will be INR.
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Whether the IRN is to be captured in the Supplier’s ERP?
The IRN (hash) will be generated by GST System using GSTIN of supplier or document creator, financial year and the unique serial number of the document/invoice. The IRN can also be generated by the seller. The serial number of invoice will be unique for a GSTIN for a Fin Year and the same has to be captured by Supplier’s ERP.
Supplier has to keep the IRN against each of its invoice. It will be advisable to keep the same in the ERP as invoice without IRN will not be a legal document. -
Whether e-invoice generated is also required to be signed again by the taxpayer?
Not mandatory. However, if a signed eInvoice is sent to IRP, the same will be accepted. The eInvoice will be digitally signed by the IRP after it has been validated. The signed e-invoice along with QR code will be shared with creator of document as well as the recipient.
Once it is registered, it will not be required to be signed by anyone else. -
Whether the facility of adding discount amount at line item-level would be mandatory in nature?
The eInvoice has a provision for capturing discount at line item level. The discounting at line item level is to be mentioned only when and if it is applicable in the particular transaction.
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Can the seller place their LOGO in the e-Invoice Template?
There will NOT be a place holder provided in the e-invoice schema for the company logo. This is for the software company to provide in the billing/accounting software so that it can be printed on his invoice using his printer. However, the Logo will not be sent to IRP. In other words, it will not be part of JSON file to be uploaded on the IRP.
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Will we be able to provide the address and bill-to party and PAN details in the e-invoice?
Yes, it will be possible to provide all these details in the placeholders provided in the schema.
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Would the Supplier be allowed to issue his own invoice and if yes, will the Invoice number and IRN be required to be mentioned?
Yes, the supplier will issue his own system’s invoice, in the standard e-invoice schema that has been published. Invoice number is a mandatory item under GST and hence for e-invoice. IRN (Hash) can be provided after the e-invoice has been successfully reported to the IRP.
As stated earlier, an E-Invoice will be valid only if it has IRN. -
The current e-invoice template provides for total discount for all the products or services. Will this be possible in the eInvoice?
Yes, there is a mechanism and placeholders to provide discounting on item level as well as total discounts on the invoice value.
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Will there be an option for linking multiple invoices in case of debit note/ credit note?
Yes, it will be allowed to link the credit/debit notes as hitherto fore.
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Will the e-invoice schema cater to reverse charge mechanism?
Yes, eInvoice system has a reverse charge mechanism reporting as well.
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Will it be possible for bulk uploading of invoices for e-invoicing as well?
Invoices have to be uploaded on IRP one at a time. The IRP will be able to handle a large sequence of invoices for registration and validate them. Essentially bulk upload will be required by large taxpayers who generate large number of invoices. Their ERP or accounting system will have to be designed in such a way that it makes request one by one. For the user, it will not make any difference.
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Will there be a time limit for e-invoice uploading for registration?
Yes, that will be notified by the Government. Without registration of e-invoice the same will not be valid. Required changes will be made in the law. Once uploaded to the invoice registration portal (IRP), it will be registered immediately, on real-time basis.
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Will it be possible to allow invoices that are registered on invoice registration system/portal to be downloaded and/or saved on handheld devices?
Yes, the IRP System after registering the invoice will share back digitally signed eInvoice for record of supplier. It will also be sent to the email address of recipient provided in the e-invoice.
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Will it be possible to print the e-invoice?
Yes, it is possible for both the seller as well as the buyer to print the invoice, using the QR code as well as signed e-invoice returned by the Invoice Registration Portal (IRP).
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Whether e-invoices generated through GST system can be partially/fully cancelled?
The eInvoice can’t be partially cancelled. It has to be fully cancelled. The e-invoice mechanism enables invoices to be cancelled. This will have to be reported to IRN within 24 hours. Any cancellation after 24hrs could not be possible on IRN, however one can manually cancel the same on GST portal before filing the returns.
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How would amendments be allowed in e-invoice?
Amendments to the e-invoice are allowed on GST portal as per provisions of GST law. All amendments to the e-invoice will be done on GST portal only.
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With the introduction of e-invoices, what are the documents need to be carried during transit of goods?
For transportation of goods, the e-way bill will continue to be mandatory, based on invoice value guidelines, as hitherto fore. This aspect will be notified by the Government when this mechanism will be notified.
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Will the exports require an eInvoice compliance.
Yes, the einvoice schema also caters to the export invoices as well. The e-invoice schema is based on most common standard, this will help buyer’s system to read the e-invoice.
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Does the e-invoice allow the declaration of export invoices/ zero rated supplies?
Yes, it allows the declaration of export invoices / zero rated supplies.
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What will be the workflow of the end to end e-invoice mechanism?
The end to end workflow will be provided by at the time of rollout of the e-invoice system.
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Will the industry be provided sufficient time for preparation for e-invoicing?
Yes, the e-invoice mechanism is expected to be rolled out in phases from 01st Oct 2020. Initially, the e-invoice mechanism is allowed for tax payers above Rs. 500 CR turnover. Subsequently, it is to be enabled for all tax payers in a phased step-wise manner. Details of these will be published subsequently.
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Can I adjust the negative liability of previous tax period in current tax period
Yes, Adjustment of negative liability of the previous tax period shall be allowed to be made along with the current tax period’s liability
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Can I make changes to suggested ITC Utilisation provided by the Portal
Yes, taxpayers can make changes to suggested ITC Utilisation provided by the Portal
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List of Interest and Late fees that will be auto populated and the ones which I have to compute
Interest and late fee to the extent of late filing of return, making late payment of taxes, uploading preceding tax periods’ invoices shall be computed by the system. Other interest due to reversals etc. shall be entered by the taxpayer on self-assessment basis
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What are new GST returns?
As per the press release issued by the Ministry of Finance dated 21-06-2019, the CBIC has proposed three new GST Returns forms, which shall be introduced in a phased manner – GST RET-1 (Monthly/Quarterly Normal), GST RET-2 (Sahaj), GST RET-3 (Sugam).
GSTR Form Description Action Plan GST ANX-1 Annexure of outward supplies, import of goods & services and inward supplies attracting reverse charge Filing of this Form is mandatory before filing of GST RET-1/2/3. GST ANX-2 Annexure of inward supplies In this Form, the details of inward supplies, uploaded by the supplier in GST ANX-1, are shown. These details have to be ‘accepted’ or ‘rejected’ or ‘marked as pending’ before filing of GST RET-1/2/3. GST RET-1/2/3 Monthly/Quarterly return In addition to the details auto-populated from GST ANX-1 and ANX-2, some other details have to be added in this Form. GST ANX- 1A Amendment to Form GST ANX-1 To make any amendment in GST ANX-1, this Form shall be filed. GST RET-1A/2A/3A Amendment to Form GST RET-1/2/3 To make any amendment in GST RET-1/2/3, this Form shall be filed. GST PMT-08 Payment of Self-assessed tax – -
What is the filling frequency for new GST returns?
GST RET-1 (Monthly / Quarterly)
GST RET-2 (Quarterly)
GST RET-3 (Quarterly)The registered person, whose aggregate turnover is more than Rs. 5 crores in the preceding financial year, shall mandatorily file GST RET-1 on monthly basis.
If aggregate turnover of a registered person is up to Rs. 5 crores in the preceding financial year, he can file returns in GST RET-1 on quarterly basis at his discretion
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What are the types of New GST Returns?
GST RET-1 (Normal)
GST RET-2 (Sahaj)
GST RET-3 (Sugam) -
What will be the Late fees and Interest applicability under new GST return?
Interest and late fees for making prescribed default (i.e., late filing of return, making late payment of taxes, uploading preceding tax period’s invoices, etc.) shall be computed by the system. Other interest due to reversals of input tax credit shall be calculated and entered by the taxpayer on self-assessment basis.
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Transition pathway of new gst returns
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What is due date of Payment of taxes?
The payment shall be made on monthly basis for all taxpayers. The payment of self-assessed liabilities shall be made by 20th of the succeeding month to which liability pertains. Thus, even if a taxpayer is opting to file return on quarterly basis, he has to make the payment of tax on monthly basis
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Which form I will have to file for payment of GST?
For taxpayers filing monthly – the payment will be through monthly RET-1(Normal)
For taxpayers filing quarterly – the payment for first two months will be through Form PMT-08 and for the third month will be through quarterly RET-1(Normal)/RET-2(Sahaj)/RET-3(Sugam) -
How should I show interest and late fees in new return?
Interest and late fees for making prescribed default (i.e., late filing of return, making late payment of taxes, uploading preceding tax period’s invoices, etc.) shall be computed by the system. Other interest due to reversals of input tax credit shall be calculated and entered by the taxpayer on self-assessment basis
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Can I switch from one return type to another return type?
The taxpayers can switch from one return form to another during the financial year in the following manner:
Switching to Form When to be exercised? Sugam or Sahaj Only once in a Financial Year at the beginning of any quarter Sahaj Sugam or GST RET-1 (Quarterly) More than once in a Financial Year at the beginning of every quarter GST RET-1 (Quarterly) -
Which annexures I will have to file under new return filling processes?
GSTR Form Description GST ANX-1 ANX-1 is annexure of outward supplies and inward supplies attracting reverse charge uploaded by supplier GST ANX-2 ANX-2 is annexure of inward supply through which recipient can claim ITC by taking actions on invoices uploaded by supplier in ANX-1 -
What is the content of ANX-1?
ANX-1 is annexure of outward supplies, inward supplies attracting reverse charge,import of services,import of goods.
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What is the content of ANX-2?
ANX-2 is annexure of inward supply through which recipient can claim ITC by taking actions on invoices uploaded by supplier in ANX-1
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Who can file Sahaj?
Return in GST RET-2 can be filed by a registered person whose aggregate turnover in the preceding Financial Year does not exceed Rs.5 crore and has only B2C outward supplies(including Nil rated, exempt and Non-GST) and/or inward supplies liable to reverse charge. Nil exempt, Non-GST are need not be declared in said return.
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Who can file Sugam?
Return in GST RET-3 can be filed by a registered person whose aggregate turnover in the preceding Financial Year does not exceed Rs.5 crore and has only B2B and/or B2C outward supplies(including Nil rated, exempt and Non-GST) and/or inward supplies liable to reverse charge. Nil exempt, Non-GST are need not be declared in said return.
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Can I opt for Sahaj or Sugam in case I have supplies through E-commerce?
No. Taxpayers opting to file quarterly return as ‘Sahaj/Sugam cannot make supplies through e-commerce operators on which tax is required to be collected under section 52.
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Can I opt for Sahaj/Sugam and take provisional ITC?
No.Taxpayers opting to file quarterly return as ‘Sahaj/Sugam shall not take credit on missing invoices.
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How do I determine my filing frequency?
The registered person, whose aggregate turnover is more than Rs. 5 crores in the preceding financial year, shall mandatorily file GST RET-1 on monthly basis.
If aggregate turnover of a registered person is up to Rs. 5 crores in the preceding financial year, he can also file returns in GST RET-1 on quarterly basis at his discretion
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Can I settle the tax liabilities through part payments?
Liability arising shall be settled through payment of tax in full by all classes and categories of tax-payers.
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Can I change the filing frequency and when?
Yes. Filing frequency can be changed from Monthly to Quarterly or vice versa only once at the beginning of a financial year.
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I have recently registered under GST, can I continue using my previous invoice number/bill series?
Yes, The return formats are changed and the invoicing rules under GST continue to apply as they were. Accordingly, the document number shall not exceed 16 characters. This can be alphanumeric with slash (/) and dash (-).
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Am I required to issue a new bill series every month, or can I continue a single series throughout the year?
The return formats are changed and the invoicing rules under GST continue to apply as they were. Accordingly, the document number shall not exceed 16 characters. This can be alphanumeric with slash (/) and dash (-).
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Can 2 digit HSN code be sufficient?
All suppliers with annual aggregate turnover of more than Rs. 5 crore and that in relation to exports, imports and SEZ supplies will upload HSN level data. HSN code shall be reported at least at six digit level for goods and at least at six digit level for services. Other taxpayers (turnover upto Rs. 5 crore) shall have an optional facility to report HSN code in the relevant table or leave it blank.
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What should be the length of invoice number?
The return formats are changed and the invoicing rules under GST continue to apply as they were. Accordingly, the document number shall not exceed 16 characters. This can be alphanumeric with slash (/) and dash (-).
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How is turnover of newly registered taxpayer considered?
For newly registered taxpayers, turnover will be considered as zero. Hence, they will have the option to file GST RET-1 (Monthly or Quarterly), Sahaj or Sugam
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Can I amend the new GST Return forms?
Form GST ANX-1 can be amended through Form GST ANX-1A and Form GST RET-1/2/3 can be amended through Form GST RET-1A/2A/3A respectively.
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When will I get credit of amended documents?
When supplier uploads the same in his ANX-1
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What is ANX -1
Details of Outward supplies, import of goods & services and inward supplies attracting reverse charge are required to be uploaded in ANX-1 by regular registered tax payers. ANX-1 is required to be uploaded for filing RET1/2/3
For Nil return no details shall be uploaded in ANX-1 -
When can I upload invoices/debit notes/credit notes in ANX-1?
Supplier may upload the data on real-time basis. For quarterly filers, the data uploading may be done either on real-time basis/at the end of the quarter/by 22nd of month following the end of the quarter. For monthly filers, the uploading of documents can be done till 17th of the month following the filing period.
(Disclaimer: Since Quarterly return filers are restricted to upload documents from 23rd till 25th of the month following the Quarter, it is assumed that Due date for Quarterly return filers is 25th of the month following the Quarter)
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Dates on which I will not be allowed to upload any document in ANX-1?
Taxpayer’s Filing Frequency & Restricted Dates
For Monthly filers: No uploading allowed between 18th – 20th of following month
For Quarterly filers: No uploading allowed between 23th – 25th of month following quarter -
Can I upload the invoices missed in GSTR-1 or GSTR3B?
Documents of the period prior to introduction of the current return filing system can be uploaded in the relevant tables of Annex 1. Only those details shall be uploaded which have not been included in the erstwhile FORM GSTR-1 or GSTR3B.
All such supplies that are declared will be accounted for payment of tax. -
Can I upload any vendor document?
Recepient cannot upload any invoices which pertain to inward supplies from a registered supplier and not liable to reverse charge.
Recepient is allowed to upload only inward supplies liable to reverse charge, import of services at an aggregated level and import of goods data at invoice/bill of entry level. -
What is “Shifting of Documents” and who can do the same
In case, the particulars of the document may be correct but the document has been reported in the wrong table. Therefore, when such documents are rejected by the recipient, instead of amending the document, a facility of shifting such documents to the appropriate table will be provided.
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Can I Upload the invoices after 10th?
Yes, but the same will be considered in next open return of the Recipient.
However, in case of monthly return filer liability on invoices uploaded between 11th to 17th of a month will be accounted in same filing period for the supplier.And, in case of quarterly return filer liability on invoices uploaded between 11th to 22nd of a month will be accounted in same filing period for the supplier.
Example: Invoice uploaded on 17th Feb- Liability will be considered in RET 1 of Jan But for Recipient same will be considered in RET 1 of Feb for the pupose of ITC.
(Disclaimer: Since Quarterly return filers are restricted to upload documents from 23rd till 25th of the month following the Quarter, it is assumed that Due date for Quarterly return filers is 25th of the month following the Quarter)
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Being a quarterly B2B Registered filer, do I have to upload invoices on real time basis or can I upload the same at the end of the quarter?
Supplier may upload the data on real-time basis. For quarterly filers, the data uploading may be done either on real-time basis/at the end of the quarter/by 22nd of month following the end of the quarter.
However, documents uploaded till 10th of the month/quarter following the filing period, shall be considered for the reporting in filing period of recipient. Any documents uploaded from 11th to 22nd shall be reflected in subsequent month of Anx-2 for the recipient and in filing period of Annex 1 of Supplier
(Disclaimer: Since Quarterly return filers are restricted to upload documents from 23rd till 25th of the month following the Quarter, it is assumed that Due date for Quarterly return filers is 25th of the month following the Quarter) -
Can Taxable or tax values be negative in Annexure-1?
Yes, wherever supplies are reported as net of debit/credit notes, the values may become negative in some cases and the same may be reported as such e.g. ( -100).
Example: In case only credit note is issued in current month for B2B supplies done in previous month, the amounts table 3B of Annex 1 will be negative -
Where should I report debit/credit note?
Debit / Credit note is issued by the supplier with respect to supplies other than supplies attracting reverse charge shall be reported in the respective tables of Annex 1
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What if debit/credit note is issued for difference in tax rate only
Taxable value shall be reported as ‘Zero’. Only tax amount shall be reported in such cases
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Do I need to report in ANX-1 the invoice number against which Debit/Credit Note is issued?
No. Unlike done currently there is no requirement to report reference invoice number for Debit/Credit Note.
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What is the meaning of “Missing Invoices” and can I take credit on the missing invoices?
Missing Invoices are the invoices which the supplier has missed out to upload in his Anx-1.
Where the supplier has failed to report the supplies after a lapse of two tax periods in case of monthly return filers and after a lapse of one tax period in case of quarterly return filers. Details of missing invoices are required to be reported in section 3L of ANNEX 1 of Recipient, in case ITC of these invoices are availed on provisional basis in ANNEX 2 by the Recipient. -
Who shall report RCM Supplies?
RCM supplies to be reported by the recipient, GSTIN wise for every supplier, net of debit/credit notes and advances paid, if any. Supplier need not report RCM Supplies
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What is the function of tab “Sec 7 applicable” in ANX-1?
In case of supply is within the state but still IGST is applicable to such transaction, then Sec7 applicable is to be mentioned as Y.
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Is there a bifurcation of B2CS and B2CL in new returns?
There is no bifurcation for B2C category. B2CS and B2CL is summed up as B2C. Such supplies are to be reported net of debit/credit notes.
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Can my supplier edit the document uploaded on the Portal?
• Document may be edited by the supplier upto 10th of the following month only if such documents are not accepted by the recipient.
• If a document has already been accepted upto the 10th by the recipient, then such document has to be reset / unlocked by the recipient and only then, it can be edited by the supplier upto the 10th of the following monthAforesaid, mechanism works for B2B Supplies, Supplies to SEZ with or without payment of tax, Deemed export
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Can I edit the document uploaded by my supplier
No, the recipient will have the option to reset / un-lock or reject a document but editing or amendment to the same shall be done by the supplier only.
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Can I Amend the Invoices for supplies to Composition/ ISD or UIN Holders?
The documents relating to such supplies may be amended by the supplier at any time and the same shall not be dependent upon the action taken (accept/reject/pending) by the recipient.
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Can I amend the uploaded documents? (Documents includes Invoices, debit notes, credit notes)
Yes, uploaded documents duly rejected by Recipient can be amended. Amendment can be done for B2B Supplies, Supplies to SEZ with / without payment of tax and Deemed Exports
In case document uploaded is accepted by the recipient. Same will have to be rejected by recipient in order to enable supplier to amend the same
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Can I claim credit of invoices marked as “Kept pending” in ANX 2?
The input tax credit in respect of pending invoices shall not be available to the recipient in the tax period in which pending action is taken.
Such credit would be rolled over to FORM GST ANX-2 of the next tax period -
My filing frequency is monthly, but my supplier’s filing frequency is quarter, how can I claim ITC on invoies which will be uploaded by the supplier at the end of Quarter?
• In case, the recipient files his return on monthly basis, all the documents uploaded by any supplier [irrespective of the fact whether the supplier files his return on monthly or quarterly (Normal, Sahaj or Sugam) basis] shall be available for acceptance by such recipient upto the 10th of the month following the month for which the return is being filed. The supplier can edit the documents so accepted by the recipient only if the same are reset/unlocked by the recipient by the said date.
• In case, the recipient files his return on quarterly (Normal, Sahaj or Sugam) basis, all the documents uploaded by any supplier [irrespective of the fact whether the supplier files his return on monthly or quarterly (Normal, Sahaj or Sugam) basis] shall be available for acceptance by such recipient upto the 10 th of the month following the quarter for which the return is being filed. The supplier can edit the documents so accepted by the recipient only if the same are re-set/unlocked by the recipient by the said date. -
What will be the impact on my ITC in case supplier fails to file the returns?
The documents uploaded in FORM GST ANX-1 for month ‘M’ by a supplier who did not file his return for the previous two consecutive tax periods (M-1 and M-2 months)shall be made available to the recipient in FORM GST ANX-2 with an indication that the credit shall not be available on such documents. In other words, such documents will be visible to the recipient but the recipient cannot claim ITC on such inward supplies. However, the recipient can reject or keep such documents pending until filing of return by the supplier. For suppliers filing return on quarterly basis, this period will be one quarter i.e. if return of one quarter has not been filed, then recipient will not be able to claim credit on the invoices uploaded during next quarter.
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What will be the impact on my ITC in case the supplier Delays/fails to upload the invoices?
If supplier delays/fails to upload the invoices, ITC on the same can be claimed by Recipient under provisional heads.
If invoices for which credit has been claimed but the details of supplies are yet to be uploaded by the supplier(s) concerned as detailed below: (i) Where the supplier has failed to report the supplies after a lapse of two tax periods in case of monthly return filers and after a lapse of one tax period in case of quarterly return filers, the recipient will have to disclose invoice level details of such supplies in Section 3L of Annex 1 -
What is Provisional ITC and when can I avail the same?
Provisional input tax credit can be taken on documents eligible for ITC but not uploaded by the suppliers. Same has to be net of ineligible credit. These details will not be auto populated.
Taxpayers opting for Sahaj/Sugam do not have an option for taking provisional ITC. -
When can I see the invoices/ debit notes/ credit notes uploaded by the supplier?
Details of documents uploaded by the supplier will be shown to the concerned recipient on near real time basis
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Timeline by which invoices I can retain under Kept Pending Action
There is no timeline defined for the same currently. It is at the discretion of Recipient the time upto which same has to kept pending
Pending action will mean that the recipient has deferred the decision of accepting or rejecting the details of the invoices. There may be multiple reasons for the same such as supplies are yet to be received or the recipient decides that ITC is not to be taken for the time being etc. -
When will the status of supplier’s return filing disclosed to me?
Status of return filing (not filed, filed) by the supplier will be made known to the recipient in FORM GST ANX-2 of the tax period after the due date of return filing is over. Recipients would be able to check the return filing status of the suppliers.
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My filing frequency is quarterly, but my recipient;s filing frequency is monthly, by when can I upload the invoices on the portal?
Supplier may upload the data on real-time basis. For quarterly filers, the data uploading may be done either on real-time basis/at the end of the quarter/by 22nd of month following the end of the quarter, irrespective of filing frequency of recipient
(Disclaimer: Since Quarterly return filers are restricted to upload documents from 23rd till 25th of the month following the Quarter, it is assumed that Due date for Quarterly return filers is 25th of the month following the Quarter)
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What will happen if I upload the invoice for the month of Jan on 12th of Feb?
For Supplier – Liability of such invoice will be considered in January. For Recipient invoice will be available for action in Annex 2 of Feb. However Recipient may take ITC on provisional basis for JAN RET 1
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When should I upload ANX-2?
ANX-2 is auto-populated and nothing is to be uploaded. Only actions can be taken.
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List of Actions allowed to Recipient in ANX-2
Recipient can
1) Accept
2) Keep Pending
3) Reject from 10th till 20th
4) No Action (reset action in case already accepted, available upto 10th only)
Pending action recipient has deferred decision to accept/reject any details of invoice may be because supplies are yet to be received or ITC is not to be taken for time being
No editing can be done to the details if document is kept in pending by RecipientIn case Recipient takes no action Document shall be deemed to be accepted on the date of filing Return
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Timeline for actions allowed to Recipient in ANX-2
1) Accept – Can be done from the time details are visible in Annex 2 till the date of filing Return
2) Kept Pending and Reject- Any document can be marked as kept pending/ Reject from 10th till date of filing of the final return RET-1/2/3 -
What will happen in case no action is taken on Annex 2 by my recipient?
In case Recipient takes no action, Document shall be deemed to be accepted on the date of filing Return
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Can I reject the document before 10th of month following the Month/ Quarter?
No
Invoices in Anx-2 can be actioned upon in following manner:
-> Accept/Reset/Unlock upto 10th of month following the Month/ Quarter
-> Accept/Reject/Keep pending after 10th of month following the Month/ Quarter -
Can accepted document be amended in ANX 2? Who can amend the document in ANX 2?
Separate functionality is to be provided to Recipient to search and reject an accepted document on which credit has already been availed. Input tax credit availed on such document shall be shown for reversal in table 4B(1) of FORM GST RET-1 which may be adjusted in table 4A(11) of FORM GST RET-1 to arrive at the amount of input tax credit availed.
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Can I edit the Invoices that are marked under Kept Pending Category?
Pending invoices will not be available for editing or amendment by the supplier until rejected by the recipient
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Can I reject the document on which I have already availed the ITC/
Separate functionality is to be provided to Recipient to search and reject an accepted document on which credit has already been availed. Input tax credit availed on such document shall be shown for reversal in table 4B(1) of FORM GST RET-1 which may be adjusted in table 4A(11) of FORM GST RET-1 to arrive at the amount of input tax credit availed.
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Where can I being the supplier reflect excess tax collections?
The supplier can report excess tax collected from the recipients, if any, in the main return (FORM GST RET-1) under any other liability in Sr. No. 8 of table 3A.
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Can I view the Balance amount available in Cash and Credit ledger before making payment?
Viewing of the balance amount available in electronic cash and electronic credit ledger will be made available before making payment
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List of payments which can be settled only in Cash
Payment of tax on account of supplies attracting reverse charge, interest, fee, penalty and others shall be made in cash only
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Can I adjust the negative liability of previous tax period in current tax period
Yes, Adjustment of negative liability of the previous tax period shall be allowed to be made along with the current tax period’s liability
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Can I make changes to suggested ITC Utilisation provided by the Portal
Yes, taxpayers can make changes to suggested ITC Utilisation provided by the Portal
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List of Interest and Late fees that will be auto populated and the ones which I have to compute
Interest and late fee to the extent of late filing of return, making late payment of taxes, uploading preceding tax periods’ invoices shall be computed by the system. Other interest due to reversals etc. shall be entered by the taxpayer on self-assessment basis
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Where can I being the supplier reflect excess tax collections?
The supplier can report excess tax collected from the recipients, if any, in the main return (FORM GST RET-1) under any other liability in Sr. No. 8 of table 3A.
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Can I view the Balance amount available in Cash and Credit ledger before making payment?
Viewing of the balance amount available in electronic cash and electronic credit ledger will be made available before making payment
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List of payments which can be settled only in Cash
Payment of tax on account of supplies attracting reverse charge, interest, fee, penalty and others shall be made in cash only
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What is ANX -1
Details of Outward supplies, import of goods & services and inward supplies attracting reverse charge are required to be uploaded in ANX-1 by regular registered tax payers. ANX-1 is required to be uploaded for filing RET1/2/3
For Nil return no details shall be uploaded in ANX-1 -
When can I upload invoices/debit notes/credit notes in ANX-1?
Supplier may upload the data on real-time basis. For quarterly filers, the data uploading may be done either on real-time basis/at the end of the quarter/by 22nd of month following the end of the quarter. For monthly filers, the uploading of documents can be done till 17th of the month following the filing period.
(Disclaimer: Since Quarterly return filers are restricted to upload documents from 23rd till 25th of the month following the Quarter, it is assumed that Due date for Quarterly return filers is 25th of the month following the Quarter)
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Dates on which I will not be allowed to upload any document in ANX-1?
Taxpayer’s Filing Frequency & Restricted Dates
For Monthly filers: No uploading allowed between 18th – 20th of following month
For Quarterly filers: No uploading allowed between 23th – 25th of month following quarter -
Can I upload the invoices missed in GSTR-1 or GSTR3B?
Documents of the period prior to introduction of the current return filing system can be uploaded in the relevant tables of Annex 1. Only those details shall be uploaded which have not been included in the erstwhile FORM GSTR-1 or GSTR3B.
All such supplies that are declared will be accounted for payment of tax. -
Can I upload any vendor document?
Recepient cannot upload any invoices which pertain to inward supplies from a registered supplier and not liable to reverse charge.
Recepient is allowed to upload only inward supplies liable to reverse charge, import of services at an aggregated level and import of goods data at invoice/bill of entry level. -
What is “Shifting of Documents” and who can do the same
In case, the particulars of the document may be correct but the document has been reported in the wrong table. Therefore, when such documents are rejected by the recipient, instead of amending the document, a facility of shifting such documents to the appropriate table will be provided.
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Can I Upload the invoices after 10th?
Yes, but the same will be considered in next open return of the Recipient.
However, in case of monthly return filer liability on invoices uploaded between 11th to 17th of a month will be accounted in same filing period for the supplier.And, in case of quarterly return filer liability on invoices uploaded between 11th to 22nd of a month will be accounted in same filing period for the supplier.
Example: Invoice uploaded on 17th Feb- Liability will be considered in RET 1 of Jan But for Recipient same will be considered in RET 1 of Feb for the pupose of ITC.
(Disclaimer: Since Quarterly return filers are restricted to upload documents from 23rd till 25th of the month following the Quarter, it is assumed that Due date for Quarterly return filers is 25th of the month following the Quarter)
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Being a quarterly B2B Registered filer, do I have to upload invoices on real time basis or can I upload the same at the end of the quarter?
Supplier may upload the data on real-time basis. For quarterly filers, the data uploading may be done either on real-time basis/at the end of the quarter/by 22nd of month following the end of the quarter.
However, documents uploaded till 10th of the month/quarter following the filing period, shall be considered for the reporting in filing period of recipient. Any documents uploaded from 11th to 22nd shall be reflected in subsequent month of Anx-2 for the recipient and in filing period of Annex 1 of Supplier
(Disclaimer: Since Quarterly return filers are restricted to upload documents from 23rd till 25th of the month following the Quarter, it is assumed that Due date for Quarterly return filers is 25th of the month following the Quarter) -
Can Taxable or tax values be negative in Annexure-1?
Yes, wherever supplies are reported as net of debit/credit notes, the values may become negative in some cases and the same may be reported as such e.g. ( -100).
Example: In case only credit note is issued in current month for B2B supplies done in previous month, the amounts table 3B of Annex 1 will be negative -
Where should I report debit/credit note?
Debit / Credit note is issued by the supplier with respect to supplies other than supplies attracting reverse charge shall be reported in the respective tables of Annex 1
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What if debit/credit note is issued for difference in tax rate only
Taxable value shall be reported as ‘Zero’. Only tax amount shall be reported in such cases
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Do I need to report in ANX-1 the invoice number against which Debit/Credit Note is issued?
No. Unlike done currently there is no requirement to report reference invoice number for Debit/Credit Note.
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What is the meaning of “Missing Invoices” and can I take credit on the missing invoices?
Missing Invoices are the invoices which the supplier has missed out to upload in his Anx-1.
Where the supplier has failed to report the supplies after a lapse of two tax periods in case of monthly return filers and after a lapse of one tax period in case of quarterly return filers. Details of missing invoices are required to be reported in section 3L of ANNEX 1 of Recipient, in case ITC of these invoices are availed on provisional basis in ANNEX 2 by the Recipient. -
Who shall report RCM Supplies?
RCM supplies to be reported by the recipient, GSTIN wise for every supplier, net of debit/credit notes and advances paid, if any. Supplier need not report RCM Supplies
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What is the function of tab “Sec 7 applicable” in ANX-1?
In case of supply is within the state but still IGST is applicable to such transaction, then Sec7 applicable is to be mentioned as Y.
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Is there a bifurcation of B2CS and B2CL in new returns?
There is no bifurcation for B2C category. B2CS and B2CL is summed up as B2C. Such supplies are to be reported net of debit/credit notes.
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Can my supplier edit the document uploaded on the Portal?
• Document may be edited by the supplier upto 10th of the following month only if such documents are not accepted by the recipient.
• If a document has already been accepted upto the 10th by the recipient, then such document has to be reset / unlocked by the recipient and only then, it can be edited by the supplier upto the 10th of the following monthAforesaid, mechanism works for B2B Supplies, Supplies to SEZ with or without payment of tax, Deemed export
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Can I edit the document uploaded by my supplier
No, the recipient will have the option to reset / un-lock or reject a document but editing or amendment to the same shall be done by the supplier only.
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Can I Amend the Invoices for supplies to Composition/ ISD or UIN Holders?
The documents relating to such supplies may be amended by the supplier at any time and the same shall not be dependent upon the action taken (accept/reject/pending) by the recipient.
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Can I amend the uploaded documents? (Documents includes Invoices, debit notes, credit notes)
Yes, uploaded documents duly rejected by Recipient can be amended. Amendment can be done for B2B Supplies, Supplies to SEZ with / without payment of tax and Deemed Exports
In case document uploaded is accepted by the recipient. Same will have to be rejected by recipient in order to enable supplier to amend the same
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Can I claim credit of invoices marked as “Kept pending” in ANX 2?
The input tax credit in respect of pending invoices shall not be available to the recipient in the tax period in which pending action is taken.
Such credit would be rolled over to FORM GST ANX-2 of the next tax period -
My filing frequency is monthly, but my supplier’s filing frequency is quarter, how can I claim ITC on invoies which will be uploaded by the supplier at the end of Quarter?
• In case, the recipient files his return on monthly basis, all the documents uploaded by any supplier [irrespective of the fact whether the supplier files his return on monthly or quarterly (Normal, Sahaj or Sugam) basis] shall be available for acceptance by such recipient upto the 10th of the month following the month for which the return is being filed. The supplier can edit the documents so accepted by the recipient only if the same are reset/unlocked by the recipient by the said date.
• In case, the recipient files his return on quarterly (Normal, Sahaj or Sugam) basis, all the documents uploaded by any supplier [irrespective of the fact whether the supplier files his return on monthly or quarterly (Normal, Sahaj or Sugam) basis] shall be available for acceptance by such recipient upto the 10 th of the month following the quarter for which the return is being filed. The supplier can edit the documents so accepted by the recipient only if the same are re-set/unlocked by the recipient by the said date. -
What will be the impact on my ITC in case supplier fails to file the returns?
The documents uploaded in FORM GST ANX-1 for month ‘M’ by a supplier who did not file his return for the previous two consecutive tax periods (M-1 and M-2 months)shall be made available to the recipient in FORM GST ANX-2 with an indication that the credit shall not be available on such documents. In other words, such documents will be visible to the recipient but the recipient cannot claim ITC on such inward supplies. However, the recipient can reject or keep such documents pending until filing of return by the supplier. For suppliers filing return on quarterly basis, this period will be one quarter i.e. if return of one quarter has not been filed, then recipient will not be able to claim credit on the invoices uploaded during next quarter.
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What will be the impact on my ITC in case the supplier Delays/fails to upload the invoices?
If supplier delays/fails to upload the invoices, ITC on the same can be claimed by Recipient under provisional heads.
If invoices for which credit has been claimed but the details of supplies are yet to be uploaded by the supplier(s) concerned as detailed below: (i) Where the supplier has failed to report the supplies after a lapse of two tax periods in case of monthly return filers and after a lapse of one tax period in case of quarterly return filers, the recipient will have to disclose invoice level details of such supplies in Section 3L of Annex 1 -
What is Provisional ITC and when can I avail the same?
Provisional input tax credit can be taken on documents eligible for ITC but not uploaded by the suppliers. Same has to be net of ineligible credit. These details will not be auto populated.
Taxpayers opting for Sahaj/Sugam do not have an option for taking provisional ITC. -
When can I see the invoices/ debit notes/ credit notes uploaded by the supplier?
Details of documents uploaded by the supplier will be shown to the concerned recipient on near real time basis
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Timeline by which invoices I can retain under Kept Pending Action
There is no timeline defined for the same currently. It is at the discretion of Recipient the time upto which same has to kept pending
Pending action will mean that the recipient has deferred the decision of accepting or rejecting the details of the invoices. There may be multiple reasons for the same such as supplies are yet to be received or the recipient decides that ITC is not to be taken for the time being etc. -
When will the status of supplier’s return filing disclosed to me?
Status of return filing (not filed, filed) by the supplier will be made known to the recipient in FORM GST ANX-2 of the tax period after the due date of return filing is over. Recipients would be able to check the return filing status of the suppliers.
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My filing frequency is quarterly, but my recipient;s filing frequency is monthly, by when can I upload the invoices on the portal?
Supplier may upload the data on real-time basis. For quarterly filers, the data uploading may be done either on real-time basis/at the end of the quarter/by 22nd of month following the end of the quarter, irrespective of filing frequency of recipient
(Disclaimer: Since Quarterly return filers are restricted to upload documents from 23rd till 25th of the month following the Quarter, it is assumed that Due date for Quarterly return filers is 25th of the month following the Quarter)
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What will happen if I upload the invoice for the month of Jan on 12th of Feb?
For Supplier – Liability of such invoice will be considered in January. For Recipient invoice will be available for action in Annex 2 of Feb. However Recipient may take ITC on provisional basis for JAN RET 1
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When should I upload ANX-2?
ANX-2 is auto-populated and nothing is to be uploaded. Only actions can be taken.
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List of Actions allowed to Recipient in ANX-2
Recipient can
1) Accept
2) Keep Pending
3) Reject from 10th till 20th
4) No Action (reset action in case already accepted, available upto 10th only)
Pending action recipient has deferred decision to accept/reject any details of invoice may be because supplies are yet to be received or ITC is not to be taken for time being
No editing can be done to the details if document is kept in pending by RecipientIn case Recipient takes no action Document shall be deemed to be accepted on the date of filing Return
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Timeline for actions allowed to Recipient in ANX-2
1) Accept – Can be done from the time details are visible in Annex 2 till the date of filing Return
2) Kept Pending and Reject- Any document can be marked as kept pending/ Reject from 10th till date of filing of the final return RET-1/2/3 -
What will happen in case no action is taken on Annex 2 by my recipient?
In case Recipient takes no action, Document shall be deemed to be accepted on the date of filing Return
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Can I reject the document before 10th of month following the Month/ Quarter?
No
Invoices in Anx-2 can be actioned upon in following manner:
-> Accept/Reset/Unlock upto 10th of month following the Month/ Quarter
-> Accept/Reject/Keep pending after 10th of month following the Month/ Quarter -
Can accepted document be amended in ANX 2? Who can amend the document in ANX 2?
Separate functionality is to be provided to Recipient to search and reject an accepted document on which credit has already been availed. Input tax credit availed on such document shall be shown for reversal in table 4B(1) of FORM GST RET-1 which may be adjusted in table 4A(11) of FORM GST RET-1 to arrive at the amount of input tax credit availed.
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Can I edit the Invoices that are marked under Kept Pending Category?
Pending invoices will not be available for editing or amendment by the supplier until rejected by the recipient
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Can I reject the document on which I have already availed the ITC/
Separate functionality is to be provided to Recipient to search and reject an accepted document on which credit has already been availed. Input tax credit availed on such document shall be shown for reversal in table 4B(1) of FORM GST RET-1 which may be adjusted in table 4A(11) of FORM GST RET-1 to arrive at the amount of input tax credit availed.
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What are new GST returns?
As per the press release issued by the Ministry of Finance dated 21-06-2019, the CBIC has proposed three new GST Returns forms, which shall be introduced in a phased manner – GST RET-1 (Monthly/Quarterly Normal), GST RET-2 (Sahaj), GST RET-3 (Sugam).
GSTR Form Description Action Plan GST ANX-1 Annexure of outward supplies, import of goods & services and inward supplies attracting reverse charge Filing of this Form is mandatory before filing of GST RET-1/2/3. GST ANX-2 Annexure of inward supplies In this Form, the details of inward supplies, uploaded by the supplier in GST ANX-1, are shown. These details have to be ‘accepted’ or ‘rejected’ or ‘marked as pending’ before filing of GST RET-1/2/3. GST RET-1/2/3 Monthly/Quarterly return In addition to the details auto-populated from GST ANX-1 and ANX-2, some other details have to be added in this Form. GST ANX- 1A Amendment to Form GST ANX-1 To make any amendment in GST ANX-1, this Form shall be filed. GST RET-1A/2A/3A Amendment to Form GST RET-1/2/3 To make any amendment in GST RET-1/2/3, this Form shall be filed. GST PMT-08 Payment of Self-assessed tax – -
What is the filling frequency for new GST returns?
GST RET-1 (Monthly / Quarterly)
GST RET-2 (Quarterly)
GST RET-3 (Quarterly)The registered person, whose aggregate turnover is more than Rs. 5 crores in the preceding financial year, shall mandatorily file GST RET-1 on monthly basis.
If aggregate turnover of a registered person is up to Rs. 5 crores in the preceding financial year, he can file returns in GST RET-1 on quarterly basis at his discretion
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What are the types of New GST Returns?
GST RET-1 (Normal)
GST RET-2 (Sahaj)
GST RET-3 (Sugam) -
What will be the Late fees and Interest applicability under new GST return?
Interest and late fees for making prescribed default (i.e., late filing of return, making late payment of taxes, uploading preceding tax period’s invoices, etc.) shall be computed by the system. Other interest due to reversals of input tax credit shall be calculated and entered by the taxpayer on self-assessment basis.
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Transition pathway of new gst returns
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What is due date of Payment of taxes?
The payment shall be made on monthly basis for all taxpayers. The payment of self-assessed liabilities shall be made by 20th of the succeeding month to which liability pertains. Thus, even if a taxpayer is opting to file return on quarterly basis, he has to make the payment of tax on monthly basis
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Which form I will have to file for payment of GST?
For taxpayers filing monthly – the payment will be through monthly RET-1(Normal)
For taxpayers filing quarterly – the payment for first two months will be through Form PMT-08 and for the third month will be through quarterly RET-1(Normal)/RET-2(Sahaj)/RET-3(Sugam) -
How should I show interest and late fees in new return?
Interest and late fees for making prescribed default (i.e., late filing of return, making late payment of taxes, uploading preceding tax period’s invoices, etc.) shall be computed by the system. Other interest due to reversals of input tax credit shall be calculated and entered by the taxpayer on self-assessment basis
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Can I switch from one return type to another return type?
The taxpayers can switch from one return form to another during the financial year in the following manner:
Switching to Form When to be exercised? Sugam or Sahaj Only once in a Financial Year at the beginning of any quarter Sahaj Sugam or GST RET-1 (Quarterly) More than once in a Financial Year at the beginning of every quarter GST RET-1 (Quarterly) -
Which annexures I will have to file under new return filling processes?
GSTR Form Description GST ANX-1 ANX-1 is annexure of outward supplies and inward supplies attracting reverse charge uploaded by supplier GST ANX-2 ANX-2 is annexure of inward supply through which recipient can claim ITC by taking actions on invoices uploaded by supplier in ANX-1 -
What is the content of ANX-1?
ANX-1 is annexure of outward supplies, inward supplies attracting reverse charge,import of services,import of goods.
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What is the content of ANX-2?
ANX-2 is annexure of inward supply through which recipient can claim ITC by taking actions on invoices uploaded by supplier in ANX-1
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Who can file Sahaj?
Return in GST RET-2 can be filed by a registered person whose aggregate turnover in the preceding Financial Year does not exceed Rs.5 crore and has only B2C outward supplies(including Nil rated, exempt and Non-GST) and/or inward supplies liable to reverse charge. Nil exempt, Non-GST are need not be declared in said return.
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Who can file Sugam?
Return in GST RET-3 can be filed by a registered person whose aggregate turnover in the preceding Financial Year does not exceed Rs.5 crore and has only B2B and/or B2C outward supplies(including Nil rated, exempt and Non-GST) and/or inward supplies liable to reverse charge. Nil exempt, Non-GST are need not be declared in said return.
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Can I opt for Sahaj or Sugam in case I have supplies through E-commerce?
No. Taxpayers opting to file quarterly return as ‘Sahaj/Sugam cannot make supplies through e-commerce operators on which tax is required to be collected under section 52.
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Can I opt for Sahaj/Sugam and take provisional ITC?
No.Taxpayers opting to file quarterly return as ‘Sahaj/Sugam shall not take credit on missing invoices.
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How do I determine my filing frequency?
The registered person, whose aggregate turnover is more than Rs. 5 crores in the preceding financial year, shall mandatorily file GST RET-1 on monthly basis.
If aggregate turnover of a registered person is up to Rs. 5 crores in the preceding financial year, he can also file returns in GST RET-1 on quarterly basis at his discretion
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Can I settle the tax liabilities through part payments?
Liability arising shall be settled through payment of tax in full by all classes and categories of tax-payers.
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Can I change the filing frequency and when?
Yes. Filing frequency can be changed from Monthly to Quarterly or vice versa only once at the beginning of a financial year.
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I have recently registered under GST, can I continue using my previous invoice number/bill series?
Yes, The return formats are changed and the invoicing rules under GST continue to apply as they were. Accordingly, the document number shall not exceed 16 characters. This can be alphanumeric with slash (/) and dash (-).
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Am I required to issue a new bill series every month, or can I continue a single series throughout the year?
The return formats are changed and the invoicing rules under GST continue to apply as they were. Accordingly, the document number shall not exceed 16 characters. This can be alphanumeric with slash (/) and dash (-).
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Can 2 digit HSN code be sufficient?
All suppliers with annual aggregate turnover of more than Rs. 5 crore and that in relation to exports, imports and SEZ supplies will upload HSN level data. HSN code shall be reported at least at six digit level for goods and at least at six digit level for services. Other taxpayers (turnover upto Rs. 5 crore) shall have an optional facility to report HSN code in the relevant table or leave it blank.
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What should be the length of invoice number?
The return formats are changed and the invoicing rules under GST continue to apply as they were. Accordingly, the document number shall not exceed 16 characters. This can be alphanumeric with slash (/) and dash (-).
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How is turnover of newly registered taxpayer considered?
For newly registered taxpayers, turnover will be considered as zero. Hence, they will have the option to file GST RET-1 (Monthly or Quarterly), Sahaj or Sugam
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Can I amend the new GST Return forms?
Form GST ANX-1 can be amended through Form GST ANX-1A and Form GST RET-1/2/3 can be amended through Form GST RET-1A/2A/3A respectively.
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When will I get credit of amended documents?
When supplier uploads the same in his ANX-1