The GST Network plans to activate an automated system from 1st December 2020 that will block the generation of E-way Bills for non-filers of monthly GST return form GSTR-3B, irrespective of turnover limits.
The Government has released the e-invoicing mandate which is going to be implemented for taxpayers with turnover INR 500 cr. from October 1, 2020 as per e-invoicing notification. The E-Invoicing API specification were released on 5th August on sandbox for testing and the production begins from 15th August 2020. Also, from now on E-invoicing and E-way Bill generation can take place simultaneously as well.
Under the e-invoicing mandate, invoices that the taxpayers generate need to be registered on the official e-invoicing portal set up by the Government called as Invoice Registration Portal (IRP) in response of which an Invoice Registration number (IRN) is generated unique to every invoice. As a step ahead, the Government has streamlined the generation of E-way Bill with E-Invoicing. And IRP can be used to generate not only IRN but also E-way bills, for the documents which qualify. Thus, depending on the data sent, the IRP system will return IRN or E-way Bill Number or both.
How to Generate E-way Bill using IRP:
As a process, the taxpayer sends invoice details to IRP and receives IRN in response along with other details like
- Signed QR code
- Acknowledgement No. (Ack No.)
- Acknowledgement date (Ack date)
- Signed Invoice Data
However, if the taxpayer also sends the transportation details along with the invoice details, then the IRP communicates with the E-Way Bill portal in real-time and generates E-Way Bill, thus saving time and efforts required at the taxpayer’s end.
So, there can be multiple scenarios where depending on the information sent to the portal, the response received varies.
A. E-Invoice and E-way Bill generated simultaneously:
There could be 2 scenarios in this category:
1. Invoice Details + Distance+ Transporter ID (Part A)
If you are sending only transporter ID and distance along with invoice details then only Part A will be generated similar to how it happens in current E-Way Bill system. The IRP system sends E-way Bill number and Generated Date (No Validity Date) back to the IRP which further goes to the taxpayers with IRN and Signed QR Code and other details like Acknowledgement number, Acknowledgement date, Status, Signed QR Code, and Signed Invoice Data.
2. Invoice Details + Transportation Details
If you are sending E-Way Bill details like distance, transport mode, vehicle details(in case of road transport) OR transport document details (in case of rail/air/ship transport) (Part B) along with invoice details then the E-Way Bill system sends E-way Bill number, Generated Date and Validity Date back to the IRP which further goes to the taxpayers with IRN and Signed QR Code and other details like Acknowledgement number, Acknowledgement date, Status, Signed QR Code, Signed Invoice Data.
B. E-Invoice generated first, E- Way bill later
In this scenario, if the e-invoice is generated first and the taxpayer has to generate E-Way bill later then the following scenarios can occur:
3. Only Invoice Details
If only invoice details are sent then IRP sends back the IRN and signed QR code along with other details like Acknowledgement number, Acknowledgement Date, Status and Signed Invoice Data.
Now later, whenever E-Way bill for said invoices needs to be generated, instead of invoice details you can send across IRN along with transportation details. Depending on the data sent following scenarios can occur:
4. IRN + Distance+ Transporter ID (Part A)
When you send transporter ID and distance along with IRN then only Part A gets generated at the E-Way Bill system which is sent back to IRP. The E-Way Bill system sends E-way Bill number and Generated Date (No Validity Date) back to the IRP which further goes to the taxpayers with same IRN and Signed QR Code and other details like Acknowledgement number, Acknowledgement date, Status, Signed QR Code, Signed Invoice Data.
5. IRN + Transportation Details
When you send E-way Bill details like distance, transport mode, vehicle details OR transport document details (Part B) along with IRN then the E-Way Bill system sends E-way Bill number, Generated Date and Validity Date back to the IRP which further goes to the taxpayers with same IRN and Signed QR Code and other details like Acknowledgement number, Acknowledgement date, Status, Signed QR Code, Signed Invoice Data.
What are the conditions for E-way Bill Generation?
Following conditions need to be met for successful E-way Bill Generation through Invoice Registration Portal
- Criteria to be met:
- HSN of at least one item in the E-way bill details belongs to goods detailed in the invoice
- E-way Bill related details are passed
- IRN is active in cases where IRN is generated first and E-way bill is generated later.
- E-Way Bill can be generated through the IRP only for invoices, not for debit and credit notes
- Validation that happens at E-way Bill Portal:
- The vehicle no. should match with the specified format of E-way bills and should exist in Vahan database
- E-waybill will not be generated if the seller or buyer’s GSTIN is blocked due to non-filing of Returns.
- The ‘from’ PIN distance to ‘to’ PIN distance as put by the taxpayer is validated by the NIC as to whether it is correct as per their records of distances between two PIN codes.
- Update E-way Bill and Other Actions
- IRP Portal helps only in Part A Generation, rest of the actions like Update Part B, Extend E-way Bill validity, generate consolidated E-way bill etc. need to be done from the E-way bill portal only. Also, there can be documents other than invoice, which need to be used to generate E-way bills such as B2C transactions, delivery challan for job work, sales return note, import etc. All such transactions which are not covered under e-invoicing but where E-way bill is required, the E-way bill number needs to be generated from the current E-way bill system.
IRN and E-way Bill Cancellation
Both IRN and E-way bill cancellation has to be done within 24 hours of generation, however, the additional condition for IRN is that there should be no active E-way bill(for the IRN). Thus, before cancelling IRN, the taxpayer needs to cancel E-way bill first, if it exists. Also, if the E-way bill is cancelled for a document, it can be regenerated for the same document, however, if an IRN is cancelled for a document, same cannot be regenerated for the same document and you need to generate new IRN using new document no. only. Cancellation of IRN and E-way bill can be carried out through the IRP portal.
Cancelling Invoice after 24 hours:
If you want to cancel the invoice after 24 hours, then you can do it in the GSTN system or you can do it by issuing a credit note. It is always better to issue a credit note and nullify it because if you delete this from GST system alone, the invoice will still be active in the IRP system.
Below is the overview for your reference:
|E-way Bill Cancellation||IRN Cancellation|
NOTE: If improper or incomplete E-way Bill details are provided then IRN will be generated and E-way Bill may show some error. Subsequently, E-way Bill by IRN can be used for E-way Bill generation.
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