Hence, notified taxpayers who are reporting e-invoices, are hereby advised not to wait for the complete auto-population, and instead proceed with preparation and filing of GSTR-1 for March, 2021 (by the due date), based on actual data as per their records.
With 1st January 2021 behind, many have taken respite with e-invoicing going live.
Last few months have been spent in a lot of back and forth between the GSP/service provider, ERP service provider, Finance team and your IT team for successful IRP(invoice registration Portal) integration and IRN generation. But with the mandate going LIVE, now starts the year of automation.
GST System is working rigorously on automating business processes. The foundation stone was laid down in 2017 with the introduction of monthly returns that streamlined business outflows and vendor transactions. This was followed by digitizing Way-bills, to understand the movement of goods. And now, getting deeper in the transaction hierarchy-GST has mandated e-invoicing, to keep a tab on daily transactions.
The long-term view of Government is to make business processes and reporting completely automated so that businesses can pay more attention to what they do best – business!
And the next step to this is –
Auto-population of e-invoice details into GSTR 1.
The e-invoice mandate that went LIVE for certain class of taxpayers from 1st October 2020 paved way for this automation. The first advisory about auto-population of e-invoice into GSTR 1 was issued on 13th November followed by second advisory issued on 30th November suggesting Government’s plan towards the same. The auto-population for the month of October and November 2020 was expected to go LIVE from Nov 2020, however same got delayed due to some technical issues. The first auto-population happened for December 2020 on 3rd December 2020 followed by October and November auto-population.
Auto-population of details from e-invoices into GSTR-1 is only a facility for the taxpayers and not final numbers from legal point of view. After viewing the auto-populated data, the taxpayers need to verify the propriety and accuracy of the amounts and other data in each field, especially from the perspective of GSTR-1 and file the same, in the light of relevant legal provisions.
Auto-population of E-Invoice Data summarised in 7 questions:
1. When will e-invoice data auto-populate?
Auto-population happens in incremental manner on T+3-day basis, i.e., for example, the data from e-invoices uploaded on 18-1-2021 would be visible in GSTR-1 on 21-1-2021.
2. Which sections of GSTR1 will be auto-populated
The below table shows all the sections present in GSTR1 and those highlighted in green are the ones that will be auto populated.
|B2B Invoices (4A, 4B, 4C,6B,6C)||B2B Amendment (9A)|
|CDNR – Credit/Debit notes (Registered) (9B)||CDNR Amendment(9A)|
|EXP – Exports (6A)||EXPA – Export Amendment (9A)|
|B2C (Large) Invoices (5A,5B)||B2C (Large) Amendment (9A)|
|CDNUR Credit/Debit notes (Unregistered) (9B) *||CDNUR Amendment (9A)|
|B2CS – B2C Others (7)||B2CS – B2C Others Amendment (10)|
|Advances Received Tax Liability (11A)||Amendment of Advances Received Tax Liability (11A)|
|Adjustment of Advances Tax Liability (11B)||Amendment of Adjustment of Advances Tax Liability (11B)|
|Nil Rated Supplies (8A, 8B, 8C, 8D)|
|Document Details (13)|
|HSN Summary * (12)|
* Partial Auto-population:
- CDNUR – only Export related will be auto-populated
- HSN Summary –only B2B and export transactions will be auto-populated. Note currently this is not auto populated yet by GSTN.
3. What is the reference date for auto-population?
The auto-population of e-invoice data into GSTR-1 is based on date of document (as reported to IRP) however, in the meanwhile, if the GSTR 1 is already filed then the auto-population details can be accessed from consolidated excel file download.For example, a document dated December, 30th, 2020 is reported to IRP on 3rd January, 2021 and where GSTR-1 for December, 2020 is not filed, then the details of that document will not be auto-populated in GSTR1 tables in any months. It will be available in the consolidated excel file download for all e-invoices pertaining to December, 2020.
4. Can I edit/modify/update invoices once it has been auto-populated?
Yes, taxpayers can edit details of e-invoices auto-populated in GSTR-1.But when the e-invoice details are modified, the ‘Source’, ‘IRN’ and ‘IRN date’ fields will be reset to ‘blank’ in respective tables of form GSTR-1. And the edited documents will be treated as freshly uploaded documents and not as auto-populated. Taxpayers are advised to modify/update only those documents where the details auto-populated from e-invoices are not as per the actual invoice issued.
5. What happens to the auto-populated details if I cancel the IRN?
After auto-population of details from e-invoices, in case of cancellation of IRN (invoice registration number) , such documents will be deleted from the respective auto-populated table. Currently, as auto-population happens in T+2 days and cancellation of IRN can be done only within 24 hours, cancelled IRNs will anyways not be considered at all while auto-population.
6. Can I add invoices in GSTR 1 even if it is not auto-populated?
Yes. There could be cases where though IRN is generated but it is not auto-populated due to some reason by GSTN. Taxpayers can add such invoices in GSTR1 on their own. It is important to note that for any transactions where IRN is applicable and the invoice is added by taxpayer in GSTR1, IRN should have been generated on that invoice. For transactions where no IRN is applicable, taxpayers are required to add in respective tables in GSTR1 themselves. Let us understand why E-invoice data may not have been auto-populated by GSTN.
7. Which other forms will get auto-populated with e-invoice details?
As GSTR1 will be auto-populated and if auto-populated data is not changed the IRN details will also be visible in the following forms:
- GSTR-2A ((Auto-drafted dynamic ITC Statement generated on the basis of e-invoices submitted by suppliers in general)
- GSTR 2B (Auto-drafted static ITC Statement generated on the basis of e-invoices submitted by suppliers in general)
- GSTR 4A (Auto-generated on the basis of e-invoices generated by suppliers of composition taxpayers)
- GSTR 6A (Auto-generated on the basis of e-invoices generated by suppliers of an Input Service Distributor)
If auto-populated data is changed then IRN details will not be visible. Also, in invoices from suppliers to whom IRN is not applicable, there will be no IRN details in these forms.
Reasons why E-Invoice Data does not get auto-populated in GSTR 1
There are multiple reasons why E-Invoice data does not get auto-populated in GSTR 1 Below is a detailed analysis of the same:
1. Document Date:
Document date is earlier to reporting date but GSTR 1 already filed by that date. If document date is December 30th 2020 and is reported to IRP on 3rd January 2021 but the GSTR-1 for December was already filed on 1st January 2021, then, the details of such document will not be auto-populated (cannot be!). But will be made available in the consolidated excel file downloadable from GSTR-1 dashboard (with error description as ‘Return already filed’). The taxpayer may thereupon take necessary action and he/she can add the invoice in their next return.
2. Wrong Supplier Type:
E-Invoicing mandate is applicable to B2B supplies and Exports only. Hence, if in e-invoice data any supplier type reported apart from these two like – ISD/NRTP/TCS/TDS will result in non-auto-population of e-invoice data
3. Supplier is a Composition Taxpayer:
E-Invoicing mandate is applicable to regular taxpayers, hence any supplier identified as Composition taxpayer for that tax period, e-invoice of those suppliers will not be auto-populated
4. Document date is prior to Supplier’s/Recipient’s effective date of registration:
While this can be clerical mistake but validation rules are built in GSTR1 to ward off such mistakes. However same rules are not built while generation of IRN and hence even though IRN gets generated, in GSTR1 no auto-population will happen in this case.
5. Document date is after Supplier’s/Recipient’s effective date of cancellation of registration:
While generating IRNs, recipient GSTIN is validated for its status i.e., whether it’s active or cancelled. However, this validation happens with the taxpayer data present on NIC portal. NIC portal syncs the data from GSTN portal and updates their database in T+1 day. Thus, it could be possible that the GSTIN is cancelled on GSTN Portal but active on NIC and so IRN was generated. However, in GSTR1 this will not be populated if the document date is after the cancellation date.
6. Invoices reported as attracting “IGST on Intra-state supply” but without reverse charge:
As per this new flag IGST on intra-state supply in e-invoicing and GSTR1, you can charge IGST even in certain specified scenarios even if its and intrastate (i.e., pos and seller state is same) However in such cases the reverse charge flag has to be compulsorily Y as per GSTR1. No such validation is present on the E-invoicing portal and IRNs were generated even with reverse charge as N
7. Buyer GSTIN and Invoice Type not in Sync:
In GSTR1, the buyer GSTIN and invoice type is validated i.e., if buyer GSTIN is an SEZ taxpayer but invoice type is put as B2B instead of SEZWP/SEZWOP the invoice is not allowed to be saved. Similarly, if buyer GSTIN is a regular taxpayer and invoice type is put as SEWP/SEWOP instead of B2B then also an error comes. However, while IRN generation no such validation is present and hence IRN is generated but it will not be auto-populated.
8. Export Without Payment and SEZ without Payment reported with Tax amounts:
In GSTR1, in the case of Export without payment and Social Economic Zone( SEZ ) without payment, the tax amounts have to be “0”. However, while generating IRN any value is allowed including “0” in tax amounts. Hence in such cases also no auto population will happen.
9. Serial No is 0:
In e-invoicing, serial number “0” is allowed however in GSTR1, serial no. “0” is not allowed. As per GSTN, such invoices will not be auto-populated.
10. White Space in places where a specific master code list is to be followed:
Any white space is counted as a character by system. Hence, care should be taken while writing for e.g., state code – e.g., “8 ”. Expected values were 08 and 8. Thus in this case if while generating IRN you have sent “8 ” then IRN may have got generated but in GSTR1 this will not be populated.
Apart from the above, some of the invoices were inadvertently missed in auto-population. GSTN released advisory confirming that same was an inadvertent gap and would be rectified and details will be pushed in the GSTR 1.
Other than the details auto-populated from e-invoices, taxpayers are required to add details of any other supplies made, in respective tables of GSTR-1.
Download of all E-invoices
GST Systemis maintaining a complete set of e-invoices (in GSTR1 format) even if you discard the auto-populated data and save own data again. You can either download these e-invoices from GST Portal or you can get these auto-populated invoices from your GST compliance software.
IRIS offers an e-invoice platform-IRIS Onyx which is seamless, integrated and one-stop solution for all GST compliance. While from the portal, you need to login to every GSTIN for getting these details, IRIS Onyx gives option for bulk fetch of these e-invoices data for multiple GSTINs and multiple months. Same can be accessed from “GST Data” Section as shown below:
For a better GST compliance
1. Ensure e-invoice process is streamlined
With e-invoicing and GSTR1 auto-population, now you will be required to ensure that all the data points sent while IRN are correctly sent. This is because of two main reasons:
(1) There is only a 24 hours cancellation window available if anything wrong goes in IRN generation. Also post cancellation same invoice cannot be sent for IRN, new invoice will have to be issued.
(2) There is no scope for editing of IRN details at all. Once an IRN is generated the data attached to that IRN cannot be changes.
Any editing of data can be done only in GSTR1. However, MIS reports of differences between IRN data and edited/deleted data will be shared with tax officers and you should have a proper explanation. If you want no edits to happen in GSTR1, it is important that while preparing data for IRN generation take into account how it will be reported in GSTR1. Also, whether you use any ASP+GSP or use offline tool of government, try to automate the extraction of data from your accounting systems and avoid manual intervention. Also, ensure that all kind of business scenarios you have are covered thoroughly while testing.
Reconcile your auto-populated E-Invoices
Though GSTR1 is being auto populated by GSTN it becomes very important to reconcile the same with your final GSTR1 data as per books. Though some of the above issues in auto population may be resolved over a period of time but not all and hence still reconciliation will be required. Also, it will help you ensure that all invoices which you want to report in GSTR1 which should have IRN indeed have got proper IRN or not and the data auto-populated by GSTN is also proper or not. It will be a double check on your own data sent for IRN generation vs. what you are finally filing in GSTR1 with GSTN. Post reconciliation what you as a taxpayer need to do is summarized below:
- If all the invoices match then you need not send the data for save again. This will ensure IRN No and Date auto-populated will remain as is.
- In case of any mismatch, you need to check which data is correct- books or IRN.
- In case if you find any invoice for which IRN is not generated but is being reported in GSTR1, then you need to check why IRN did not get generated.
- In case if you find any invoice for which IRN is generated but is cancelled in your systems, then you may have to delete those invoices while reporting in GSTR1. Ideally IRN should also be cancelled if invoice is cancelled but IRN cancellation is allowed only within 24 hours. So, in case you could not cancel, GSTN allows you to delete the invoice from GSTR1.
- Also, the cases where IRNs are generated but not auto-populated due to validations at GSTN, you need to revisit the data being sent for IRN. You may have to make some changes in that.
Thus, unless you reconcile you won’t be able to make out which invoices you need to take care of before filing GSTR1.
IRIS will be releasing an e-invoicing and GSTR 1 Reconciliation module for all IRIS Sapphire (GST Solution) The module will help users to reconcile their IRN details with the auto-populated details from the GSTN. With this module, users can fetch e invoices data, reconcile and check the mismatches to ensure correct data is present in IRIS portal as well as GSTN portal.