It has been more than three years now that you have been filing your invoice level sales data in GSTR-1 and paying liabilities after adjusting Input tax credit (ITC) through GSTR 3B. During these three years there have been so many changes with respect to rates applicable, provisional ITC rules, credit note delinking etc. Among all these changes a new concept of E-invoicing was introduced in May 2019 for the first time, although the final e-invoice implementation plan was released in 2020 in phased manner.
Currently as it stands, E-invoicing is applicable to all companies with turnover 500 crores and above from 1st October 2020 and for companies with turnover 100 crores to 500 crores with effect from 1st January 2021. It is also anticipated that it will become applicable to companies with turnover less than 5 crores in the new financial year 2021-2022.Some sectors like banking, insurance, financial institutions including NBFCs, GTA, Suppliers of Passenger transportation, multiplexes and SEZ units are exempted from this mandate.
Life after E-invoicing
Conceptually, E-invoicing means registering your invoice with government and giving it a legal validity. While registering this invoice a unique no called Invoice Registration Number (IRN) is received back from NIC along with some other details like Acknowledgement number, date, Signed QR code and Signed invoice.E-invoicing is applicable only to Regular Tax Invoices, Credit notes, Debit notes and on transactions with registered counterparties and exports. However, we know that GSTR 1 consists of not just these invoices and transactions, but also B2C, Advances, NIL etc.
Now let us understand what exactly has changed with E-invoicing for all such transactions with the help of this tabular representation:
|Activity||Before E-invoice||After E-invoice|
|E-way Bill for movement of goods||
|GSTR 1 preparation||
GSTR-1 -Post e-invoicing
Below are the sections that will be impacted :
1. B2B/Exports – Auto-populated from E-invoice
There are four sections in which data will be auto-populated in GSTR1. B2B/CDNR/EXP/CDNUR (related to Export invoices).
This clearly means that whenever you send data for e-invoicing or do your e-invoice implementation, you need to take into consideration the fact that GSTR1 will be auto populated. Thus, for example if you are in doubt what should be the invoice value in e-invoicing, consider what you would want to report in GSTR1. Same goes for any other fields that are common.
Now you must be wondering if auto population is being done by GSTN for these sections then,you just need to add other sections and file the return? No, for all such transactions covered under e-invoicing, you need to check the auto populated data for any differences in values or missing documents in auto population etc. An automated reconciliation module will help you achieve this. IRIS is going to release the same soon. Read auto-population of e-invoice details into GSTR 1.
2. B2C – Uploaded by taxpayer
There are two categories of B2C transactions as defined by government.
1. B2C Large –
This section includes all Interstate B2C transactions which have invoice value of greater than equal to 2.5 lakhs. In this case invoice level data is to be reported. Credit notes related to these B2C (Large) invoices will have to be reported in CDNUR section.
2. B2C (Others) Other than B2C (Large)
This section includes all Interstate B2C transactions which have invoice value of less than 2.5 lakhs and also all intrastate transactions. In this case, data is to be reported at an aggregate level i.e., Taxable values and tax values aggregated at Place of Supply (pos) and tax rate level.
With respect to GSTR1 reporting, nothing changes for B2C transactions and these are to be reported as they are currently being done. One additional compliance is though added for companies with turnover above 500 cr. to have a self-generated dynamic QR code for all B2C transactions which will promote digital payments
3. Advances -Tax paid – Uploaded by taxpayer
Under GST, tax is payable on advanced received from customer also and subsequently when an invoice is issued against the advance, the tax against that invoice is adjusted with already paid tax. Hence there are two separate sections in GSTR1 for reporting these transactions Advances Received and Advance Received Adjusted. Under both these sections too the data is reported at an aggregate level i.e., Taxable values and tax values aggregated at Place of Supply (pos) and tax rate level. The current flow of GSTR1 for this section remains unchanged.
4. Nil, Exempt, and Non-GST Supplies – Uploaded by taxpayer
Nil, Exempt Non-GST has a separate table in GSTR1 where the amounts are again reported at an aggregated level. Let us understand now whether will there be any change in reporting of transactions of Nil, Exempt and Non-GST in GSTR1 due to introduction of e-invoicing?Usually, a Bill of Supply is issued when there is a sale of Nil, Exempt, Non-GST goods/services. Bill of Supply is not covered under E-invoicing and hence no IRN will be generated. However, what happens when there is a regular tax invoice which has taxable as well as Nil, Exempt and Non-GST in same invoice and IRN is generated?
GST Invoicing Rules requires separate documents to be issued for taxable supplies and Nil, exempt and non-GST supplies in case of transactions between registered parties. As referred in the rules, tax invoice is for taxable supplies and for others where no GST is charged, is Bill of Supply.However, issuing a combined invoice for taxable and nil supplies has been a common practice. In case of such combined reporting, taxpayers had the option of disclosing the full invoice in the respective section of GSTR 1 or as part of the NIL table.
With e-invoicing mandate and clarifications provided in the webinars conducted by GSTN and NIC, following are the important points to be noted –
- Only regular tax invoices, debit notes and credit notes should be sent for IRN generation. Bill of Supply is not to be sent for IRN generation
- All invoices sent for IRN generation will also be populated in GSTR1 by GSTN.
- If there is a transaction involving Taxable and Nil,Exempt, Non-GST supplies together, then also there should be two documents one Tax invoice for Taxable and second Bill of supply for Nil, Exempt, Non-GST.
- In case of Export and SEZ supplies, there should not be a Bill of Supply as these are not Nil/Exempt/Non-GST supplies but these are zero rated supplies. In case of Export and SEZ supplies if still there is a bill of supply issued and in GSTR1 it is being reported at invoice level in export section, then IRN can be generated for such document considering the same as a regular tax invoice instead of Bill of Supply by sending document type as INV. Otherwise, there will be difference in e-invoicing and GSTR1.
In case you still do combined reporting of taxable and Nil, Exempt and Non-GST, then such Tax invoices will go for IRN generation. While sending data for IRN, the taxable portion will have values reported against respective tax rates whereas the Nil, Exempt, Non-GST line items will have values reported with a tax rate of 0%. Hence while auto-population of GSTR1 also when these invoices will go in respective tables, the Nil, Exempt Non-GST portion will be reflected under 0% tax rate.
If till now, in GSTR1 you have been splitting such invoice by reporting taxable portion in the respective table at invoice level and reporting Nil, Exempt Non-GST in Nil table, you may have to revisit your existing practice. Now, even though GSTR1 data is auto-populated, it is allowed to be edited. Hence in above cases also even if Nil, exempt is auto-populated in your normal B2B table due to common invoice, you can delete the nil exempt part from there and add in the Nil exempt table. However, this will mean that IRN details will get removed from such invoices. Also, GSTN has mentioned time and again that any differences between e-invoicing data and GSTR1 actual filed data will be shared with tax officers. Thus, whatever stand you take for changing auto-populated data, you may have to explain the same if you get any show cause notices.
IRIS already has provided the flexibility to the taxpayers to decide the approach they want to follow as in GSTR1 also there was a flexibility of reporting Nil exempt in B2B table/Nil table as per taxpayers wish. Post e-invoicing also, different taxpayers can still have different approaches and hence we have retained this flexibility. So, taxpayers can still decide in which table they want to report the Nil, Exempt, Non-GST and accordingly send the data in IRIS input format while filing of GSTR1 like they are currently doing.
Our recommendation for GSTR-1 – post e-invoicing however has always been as follows:
- While extracting IRN data make sure you calculate all values correctly and consider what values you are going to report in GSTR1.
- In case of Nil exempt plus taxable in single invoice then do not split the value of nil exempt in nil table as auto-populated data will be in the respective table.
- For Export transactions you need to be more careful as refunds are processed currently based on GSTR1 data and IRN data may also be considered soon. Thus, do not issue any Bill of Supply. Always have a regular tax invoice and send for IRN generation.
5. Other miscellaneous sections – Uploaded by taxpayer
In following sections, the taxpayers will have to continue doing the way they are currently doing.
(a) Document Details – List of documents issued and cancelled during the month
(b) HSN Summary – Though GSTN had mentioned that this will be auto-populated based on e-invoicing data, currently it is not yet auto-populated. Also, even if its auto-populated if you have B2C transactions then you may anyways have to change the data
(c) Amendment for sections for which IRN is applicable – Amendments sections will be kept open in case you want to amend any data even for invoices on which IRN is generated. However, it may impact the ITC of your customer if any amendment is done in B2B section. There is no IRN generation flow added for revised document in the e-invoicing mandate. You may instead issue a credit/debit note for any difference in values and generate IRN for the same as well. In case there is change in counterparty or place of supply etc., you can issue a credit note of full amount to nullify the effect of original invoice and generate a new invoice with new correct data.
(d) Amendment for other sections – These will continue to work as they currently do.
So many complications, right? Don’t worry, discuss all the scenarios within your taxation teams to finalize a common approach and while implementation of e-invoicing itself ensure all corrective actions are taken. This will help in retaining the auto-populated data and face minimal challenges while GSTR1 compliances. Be vigilant and stay compliant.
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