IFF or the Invoice Furnishing Facility came into practice on 10th November 2020 after The Central Board of Indirect Taxes & Customs (CBIC)’s notification 82/2020.
Being the first month for the January-March 2021 quarter, the first cut-off date was 13th February 2021 for January 2021. The Invoice Furnishing Facility (IFF) started from 1st January 2021.
What is Invoice Furnishing Facility (IFF)?
Invoice Furnishing Facility (IFF) is an optional facility made available as per Rule-59(2) of the CGST Rules, 2017 and if the taxpayer does not opt for it, he/she can directly upload their invoices in GSTR 1. To ease the compliance burden, the system has assigned quarterly frequency to small taxpayers automatically. Payment can be made in the first two months by a simple challan in FORM GST PMT-06.
Points to note about Invoice Furnishing Facility:
- IFF can be used by Quarterly Returns and Monthly Payment (QRMP ) taxpayers and also by regular taxpayers with annual aggregate turnover of up to Rs.5 crores.
- Rs. 50 lakh is the total value of invoices that can be uploaded per month under IFF.
- Since this is an optional facility, taxpayers will not attract any late fee for non-usage.
- The invoices from the last month of a quarter needs to be uploaded in the GSTR-1 return only.
- If the invoices are uploaded in IFF then there is no need to re-upload in GSTR 1.
- All the details that are uploaded in IFF will get reflected in GSTR-2A and GSTR-2B.
Why is Invoice Furnishing Facility introduced?
The QRMP scheme allows small taxpayers with annual turnover less than Rs. 5 crores to file quarterly returns i.e. GSTR-1 and GSTR-3B. This has reduced taxpayer’s compliance burden but has given rise to a problem of claiming ITC (Input Tax Credit). As the returns are filed quarterly, the counterparty of QRMP taxpayers had to wait until the end of the quarter to claim their ITC. ITC can be claimed only when the invoice appears in his/her GSTR 2A / GSTR-2B, thus counterparty of QRMP taxpayer had to face a lot of delay in the claim process of their ITC. This is why the IFF facility has been introduced.
Using IFF, QRMP taxpayers can upload selective or all B2B invoices on the GST portal for the first two months of the quarter and their counterparties can claim their Input tax credit( ITC ) without any delay.
Details to be submitted for the Invoice Furnishing Facility (IFF)
Under this IFF, only the below sections of B2B transactions as per GSTR 1 are allowed to be uploaded, saved and filed.
- Table 4 – Taxable outward supplies made to registered persons (including UIN-holders) other than supplies covered by Table 6
- 4A. Supplies other than those (i) attracting reverse charge and (ii) supplies made through ecommerce operator
- 4B. Supplies attracting tax on reverse charge basis
- 4C. Supplies made through e-commerce operator attracting TCS (operator wise, rate wise)
- Table 6 – Zero rated supplies and Deemed Exports
- 6B. Supplies made to SEZ unit or SEZ Developer
- 6C. Deemed exports; Note here 6A i.e. Export data is not allowed to save through IFF
- Table 9 – Amendments to taxable outward supply details furnished in returns for earlier tax periods in Table 4and 6 [including debit notes, credit notes issued during current period and amendments thereof
- 9A. If the invoice details furnished earlier were incorrect
- 9B. Debit Notes/Credit Notes/Refund voucher [original]
- 9C. Debit Notes/Credit Notes/Refund voucher [amendments thereof]
Using the Invoice Furnishing Facility (IFF)
The GST portal gave a timeline to opt-in or out of the scheme which was 31st January 2021 for the quarter January-March 2021. If the small taxpayers stayed in the scheme, the facility was given for the first two months of the quarter only. The B2B invoices needed be uploaded in IFF from 1st to the 13th of the month subsequent to the relevant month.
Use IRIS for IFF – How IRIS Sapphire can help?
As the API’s for IFF and GSTR 1 are same hence IRIS Sapphire User can easily use GSTR 1 feature for uploading and saving invoices on GSTN portal. So here QRMP taxpayer, can upload data for first two months of quarter for sections like B2B invoices, Debit and credit notes of B2B invoices and if there any amendments for these sections.
Kindly note that IFF also needs to be filed for the first two months till 13th of subsequent month. If it is not filed till 13th of subsequent month then IFF will get expire for that month. Hence data uploaded for these months in IFF has to be deleted first from the uploaded month and then later upload it in 3rd month of the quarter as GSTR 1 data. And then file GSTR 1.
For Quarter Jan – Mar 2021, if you uploaded data in Jan 2021 period as IFF then you need to file this IFF till 13th of Feb 2021. If failed to file on time then you need to delete this data from Jan 2021 and then need to upload and save this data in Mar 2021 filing period i.e. your Quarterly GSTR 1.
If IFF is filed by 13th then this January 2021 data is not required to upload and save again in March as GSTR 1.
How do I declare B2C supplies in IFF for first two month of quarter if I have opted for QRMP?
Answer: Supplies made to unregistered persons (also called B2C supplies) are not required to be declared in IFF. These may be declared in FORM GSTR-1 for the quarter.
How will I reconcile the values declared in IFF & GSTR-1 with quarterly GSTR-3B?
Answer: Taxpayers will be provided with a draft GSTR-3B, which will contain the details of the liability to be paid by taxpayers in the quarterlyGSTR-3B. This will be prepared on the basis of the supplies declared in FORM GSTR-1 for the quarter. It will also contain data from the optional IFF, if any is filed in either of the first two months of the quarter. The said system computed values will also be auto-populated in quarterlyGSTR-3B.
It is mentioned that “Any IFF which is not filed till the due date of 13th of the subsequent month will expire.”
(a) If a taxpayer has uploaded an invoice in Jan 2021 and did not file it by 13th of the subsequent month, then will this invoice still be reflected in GSTR2A of the counterparty with CFS as N?
Answer: It will CFS as “N”. One should delete these invoices and report in the next month.
(b) Will the same invoice be allowed to be uploaded in Quarterly filing of Jan to March as IFF was not filed in Jan 2021?
Answer: It should be deleted and uploaded. We are planning to provide, some migration feature on portal. You can also provide it by giving an option to import these invoices in to another period.
(c) If answer to (a) and (b) is yes then in such case, one invoice will be present in GSTR2A twice, once in Jan month with CFS as N and second time in March month with CFS Y?
Answer: If IFF will be expired on non-filing of return by 13th, the invoices should also be removed from 2A. Or Auto population in 2A from IFF should happen only after filing of IFF and not before so that this scenario of CFS N does not come only.
When will the APIs for these be released? Will it be the same GSTR-1 APIs to be used or new APIs will have to be integrated.
Answer: Same GSTR1 API will work with business validation to only allow four sections in case of IFF.
How will GSTR3B auto-compute work in these cases? As 3B will also be quarterly in QRMP, will the Jan 2021 and Feb 2021 IFF invoices (if IFF is filed) be considered in Jan to Mar quarter 3B?
Answer: Yes, IFF invoices will be considered.
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