Recent amendments in GST withcomprehensive coverage of QRMP scheme,ITC utilization restriction and E- Invoicing
CA AANCHAL ROHIT KAPOORCA NEETU SHARMA
M. No. 9988692699, 9888069269,[email protected]
07-01-2021 CA AANCHAL KAPOOR 1
Sr. No. Notification Remarks
1 Notification No. 82/2020 – Central Tax, dated 10.11.2020.
Makes the Thirteenth amendment (2020) to the CGST Rules 2017.
2 Notification No. 84/2020 – Central Tax, dated 10.11.2020.
Notifies class of persons under proviso to section 39(1) of the CGST Act.
3 Notification No. 85/2020 – Central Tax dated 10.11.2020.
Notifies special procedure for making payment of tax liability in the first two months of a quarter
QRMP Applicable
from 01.01.2021
Registered person having aggregate turnoverIN preceding FY up to Five (5) crore rupees
07-01-2021 CA AANCHAL KAPOOR 2
Section Rules Particulars
37 59 Furnishing details of outward supplies
38 59 and 60 Furnishing details of Inward supplies
39 61 to 67 Furnishing details of returns
Sections & Rules to be considered
07-01-2021 CA AANCHAL KAPOOR 3
Whether tax required to be paid if there is Nil liability in preceding
quarter
Switching from fixed methodto self assessment method
Eligibility for QRMP Scheme
Interest liability if amount deposited in first two
months is less than actual liability
Refund if tax paid in first two months is
more than actual tax liability
Late Fee on Delayed Payment of PMT-06
GSTR-1 monthly or quarterly
Conditions of scheme
07-01-2021 CA AANCHAL KAPOOR 4
RULE 61Form & Manner of Furnishing Return
3B made quarterly for • Agg Turnover upto
Rs. 5 cr. As per 84/2020
Monthly Filling
Quarterly Filling
Pay Tax for each of firsttwo months of the qtr =Form GST PMT-06 by25th day of succeedingmonth
❑ The amount deposited through PMT-06 for 1st and 2nd month will remain inthe cash ledger and will be adjusted on filing 3B at the end of Quarter.
❑ Any claim of refund of such amount lying in balance in the electronic cashledger, if any, out of the amount so deposited shall be permitted only afterthe return in FORM GSTR-3B for the said quarter has been filed.
20th of Succeeding
MonthAs per States
22nd or 24th day of month of
Succeeding quarter
Pay Tax through GSTR-3B
Effective from 01.01.2021
07-01-2021 CA AANCHAL KAPOOR 6
SCREEN SHOT AGGREGATE TURNOVER
07-01-2021 CA AANCHAL KAPOOR 7
Aggregate annual turnover for the preceding financial year shall be calculated in the common portal taking into account
the details furnished in the returns by the taxpayer for the tax periods in the preceding financial year
Registered Person
Intending to file
U/s 39(1) i.e. 3B
Quarterly Indicate his preference for furnishing of return on aquarterly basis, electronically, on the common portal,from the 1st day of the second month of thepreceding quarter till the last day of the first monthof the quarter for which the option is beingexercised:
Example:- Option for filing return for Jan- March, 2022 is to be selected❑ Option to be selected on the portal from 1st Nov,2021 to 31st Jan,
2022.(subject to conditions)
Manner of opting for furnishing Quarterly Return-3B
07-01-2021 CA AANCHAL KAPOOR 8
Fixed Quarters in GST
RULE 61A
RULE 61A(1)Manner of opting for furnishing Quarterly Return-3B New Rule
Inserted
Once option exercised, RP shallcontinue to furnish return on qtrlybasis future tax periods unless
RP becomes ineligible for furnishing the returnon a quarterly basis as per the conditions andrestrictions notified in this regard
or opts for furnishing of return on a monthlybasis, electronically, on the common portal:
If T.O. exceeds 5 crores being in
QRMP
RP shall opt for furnishing of return on a monthly basisFrom the first month of the quarter, succeeding the quarter during which his aggregate turnover exceeds5 crore rupees.
N. N. 84/2020-CT
e.g. Apr,2021 to June ,2021 Quarterly filling but exceeded Rs. 5 cr in this quarter in May, from July shall opt monthly filling
07-01-2021 CA AANCHAL KAPOOR 9
RULE 61A(2)
example: A registered person intending to avail of the Scheme for the quarter ‘July to September’ can exercise hisoption during 1st of May to 31st of July. If he is exercising his option on 27th July for the quarter (July to September), insuch case, he must have furnished the return for the month of June which was due on 22/24th July
All Last returns due on the date of exercising such option must have been furnished.Condition
Quarterly Return Monthly Payment Scheme
Circular No. 143/13/2020- GST
Registered persons are not required to exercise the option every quarter. Where such option has been exercised once, they shall
continue to furnish the return as per the selected option for future tax periods, unless they revise the said option
Opting out ofscheme
Opting out of the Scheme for a quarter will be available from first day of second month of preceding quarter to the lastday of the first month of the quarter
QRMP Scheme is GSTIN wise and therefore, distinct persons as defined in Section 25 of the CGST Act(different GSTINs on same PAN) have the option to avail the QRMP Scheme for one or more GSTINs. In otherwords, some GSTINs for that PAN can opt for the QRMP Scheme and remaining GSTINs may not opt for theScheme
07-01-2021 CA AANCHAL KAPOOR 10
Timeline for opting IN/OUT from QRMP Scheme
• 1st August to 31st Oct
• 1st Nov. to 31st Jan
• 1st May to 31st July
• 1st Feb to 30th April
April-June
July-Sept
Oct-Dec
Jan-March
07-01-2021 CA AANCHAL KAPOOR 11
Notification 84/2020-CT
Deemed Option forGSTR-3B based GSTR-1
RP furnished the return 3B for the tax period October, 2020 on or before 30th November, 2020
Sl. No. Class of registered persons Deemed option—3B
1 Aggregate turnover of up to 1.5 crore rupees, Form GSTR-1 ---Quarterly in C/Y Quarterly return
2 Aggregate turnover of up to 1.5 crore rupees, Form GSTR-1 --- Monthly in C/Y Monthly return
3 Aggregate turnover >1.5 crore rupees =< 5 crore rupees in P/Y Quarterly return
RP may change default option electronically on the common portal, during the period from the 5th day of December,2020 to the 31st day of January, 2021.
07-01-2021 CA AANCHAL KAPOOR 12
Eligibility
F.Y. 2019-20
Aggregate T.O.
4 Cr
F.Y. 2020-21Up to Nov.
3.5 Cr
Eligible
1
F.Y. 2019-20
F.Y. 2020-21Up to Nov.
2
4 Cr
6.5 Cr
07-01-2021 CA AANCHAL KAPOOR 18
Deemed Quarterly
Eligibility
F.Y. 2019-20
Aggregate T.O.
6 Cr
F.Y. 2020-21Up to Nov.
2 Cr
Eligible
3
F.Y. 2019-20
F.Y. 2020-214
4 Cr
4.5 Cr
F.Y. 2021-22 Upto May 7 CrUpto 1st Qtr of 2021-22,thereafter not eligible07-01-2021 CA AANCHAL KAPOOR 19
F.Y. 2019-20
F.Y. 2020-21Up to Nov.
Not eligible for QRMP
Composition Taxpayer
Input Service Distributor
Non Resident Taxable Person
Department orestablishment ofState/ CentralGovt.
If one crossesturnover of Rs. 5Crore, during thequarter
07-01-2021 CA AANCHAL KAPOOR 21
MonthlyDeposit forMonth 1 &Month 2
Fixed SumMethod
Self AssessmentMethod
35% of the tax paid in cashin the previous quarter
100% of tax paid in cash inlast month of the previousquarter
Actual Output less Input
07-01-2021 CA AANCHAL KAPOOR 23
Available only if person was registered for
complete preceding Tax Period
Notification 85/2020-CT
Facilitate ITC calculationasper GSTR-2B
RP is free to avail either of the two tax payment method above in any of the two months of the quarter.
Self AssessmentMethod
A complete tax period means a tax period in which the person is registered from the first day of the tax period till the last day of the tax period.
07-01-2021 CA AANCHAL KAPOOR 24
Complete Tax Period for Fixed Sum Method
Consequences in case of cancellation of registration
• In case of cancellation of registration,
• such person during any of the first two months of the quarter ,
• he is still required to furnish return in Form GSTR-3B for the relevant tax period.
Example :- If one is opting for the scheme on 25th January for Jan-Mar, 2021 quarter, then if got registration on 10th
December, then he cannot opt for Fixed Payment Method, as he was not registered on first day of Tax Period.
07-01-2021 CA AANCHAL KAPOOR 26
✓ The Amount Deposited in First Two Months will be OFFSET ON FILLING OF GSTR-3B.
✓ Any claim of refund in respect of the amount deposited for the first two months of a quarter for payment of tax shall
be permitted only after the return in FORM GSTR-3B for the said quarter has been furnished.
✓ Further, this deposit cannot be used by the taxpayer for any other purpose till the filing of return for the quarter
Notification 85/2020-CT
Special procedure for payment of tax under proviso to sec. 39(1)
Deposit of an amount in the electronic cash ledger equivalent to, -
i. 35%. of the tax liability paid by debiting the electronic cash ledger in the return for the preceding quarter where the return is
furnished quarterly; or
ii. the tax liability paid by debiting the electronic cash ledger in the return for the last month of the immediately preceding
quarter where the return is furnished monthly:
Provided that no such amount may be required to be deposited-
a) for the first month of the quarter, where the balance in the electronic cash ledger or electronic credit ledger is adequate for the tax
liability for the said month or where there is nil tax liability ;
b) for the second month of the quarter, where the balance in the electronic cash ledger or electronic credit ledger is adequate for the
cumulative tax liability for the first and the second month of the quarter or where there is nil tax liability:
Provided further that registered person shall not be eligible for the said special procedure unless he has furnished the return for a
complete tax period preceding such month.
Explanation- For the purpose of this notification, the expression ―a complete tax period means a tax period in which the
person is registered from the first day of the tax period till the last day of the tax period.
Effective from 01.01.2021
07-01-2021 CA AANCHAL KAPOOR 27
Notification No. 85/2020-CTPayment system
Pay tax every month by way of making a deposit of an amount in the electronic cash ledger equivalent to,
i. thirty five per cent. of the tax liability paid by debiting the electronic cash ledger in the
return for the preceding quarter where the return is furnished quarterly; or
ii. the tax liability paid by debiting the electronic cash ledger in the return for the last month of the
immediately preceding quarter where the return is furnished monthly:
no such amount may be required to be deposited-(a) for the first month of the quarter, where the balance in the electronic cash ledger
Orelectronic credit ledger is adequate for the tax liability for the said month
Orwhere there is nil tax liability ;
(b) for the second month of the quarter, where the balance in the electronic cash ledger or electronic creditledger is adequate for the cumulative tax liability for the first and the second month of the quarter or wherethere is nil tax liability:
Proviso
Effective from 01.01.2021
07-01-2021 CA AANCHAL KAPOOR 28
Monthly Payment of Tax
The registered person under the QRMP Scheme would be required to pay the tax due in each of the first two months of the quarterby depositing the due amount in FORM GST PMT-06, by the twenty fifth day of the month succeeding such month.
While generating the challan, taxpayers should select “Monthly payment for quarterly taxpayer” as reason for generating the challan
Methods for monthly payment of tax
Fixed Sum Method
Self assessment Method
A facility is being made available on the portal for generating a pre-filled challan inFORM GST PMT-06 for an amount equal to• 35% of the tax paid in cash in the preceding quarter where the return was
furnished quarterly; or• equal to the tax paid in cash in the last month of the immediately preceding
quarter where the return was furnished monthly.
In case the last return filed was on quarterly basis for Quarter Ending March, 2021:
Tax paid in Cash in Quarter (January -March, 2021)
Tax required to be paid in each of the months – April and May, 2021
CGST 100 CGST 35
SGST 100 SGST 35
IGST 500 IGST 175
Cess 50 Cess 17.5
In case the last return filed was monthly for tax period March, 2021:
Tax paid in Cash in March, 2021
Tax required to be paid in each of the months – April and May, 2021
CGST 50 CGST 50
SGST 50 SGST 50
IGST 80 IGST 80
Cess - Cess -
The said persons, in any case, can pay the tax due by consideringthe tax liability on inward and outward supplies and the inputtax credit available, in FORM GST PMT-06.In order to facilitate ascertainment of the ITC available for themonth, an auto-drafted input tax credit statement has beenmade available in FORM GSTR2B, for every month.
Monthly tax payment through this methodwould not be available to those registeredpersons who have not furnished the return fora complete tax period preceding such month. Acomplete tax period means a tax period inwhich the person is registered from the first dayof the tax period till the last day of the taxperiod
07-01-2021 CA AANCHAL KAPOOR 29
Return Filing Structure
Existing till 31.12.2020
Aggregate Turnover in previousFinancial Year
More than 1.5 cr. Up to 1.5 Cr.
GSTR-1--- MonthlyGSTR-3B--Monthly
GSTR-1--- MonthlyGSTR-3B--Monthly
GSTR-1--- QuarterlyGSTR-3B--Monthly
From 01.01.2021
Aggregate Turnover in previousFinancial Year
More than 5 cr. Up to 5 Cr.
GSTR-1--- MonthlyGSTR-3B--Monthly
GSTR-1--- MonthlyGSTR-3B--Monthly
GSTR-1--- QuarterlyGSTR-3B--Quarterly
07-01-2021 CA AANCHAL KAPOOR 31
Head wise Payment issue
07-01-2021 CA AANCHAL KAPOOR 32
Preceding Month Only Cash Paid in CGST/SGST
QRMP First month Payment is required in IGST
What would be auto-generation of Challan by the portal if it generated for IGST or vice-versa and supply is otherwise?
✓ It will be CGST/SGST
✓ It is pertinent to note that FOR Cash payment to be utilized in other head, one can use PMT-09.
Nil Liability
07-01-2021 CA AANCHAL KAPOOR 33
❑ In case the balance in the electronic cash ledger and/or electronic credit ledger is adequate for the tax due (for the
first month or cumulative dues in the second month) or
❑ where there is a nil tax liability,
the registered person may not deposit any amount for the said months.
Example
Tax paid in Jan – Mar 2021 ---------------------------------------------------- 0.00For Apr. 2021 not required to pay tax.
Returns under QRMP Scheme
GSTR-3B By 22nd or 24th of the monthsucceeding the quarter
For 1st Quarter of 2021-22 duedate 22nd /24th July
GSTR-1 By 13th of the monthsucceeding the quarter
For 1st Quarter of 2021-22 duedate 13th July
07-01-2021 CA AANCHAL KAPOOR 34
The registered persons opting for the Scheme would be required to furnish the details of an outward supply in FORM GSTR-1 quarterly as per rule 59 of the CGST Rule.
The Form 'PMT 06' is required to be used for tax payment. The due date of the tax payment is the 25th of thesucceeding month. While generating the challan, taxpayers should select "Monthly payment for the quarterlytaxpayer" as a reason for generating the challan.
Interest Applicability
No interest would be payable in case the tax due is paid in the first two months of the quarter by way of depositingauto-calculated fixed sum amount as detailed in para 6.1(a) above by the due date.In other words, if while furnishing return in FORM GSTR-3B, it is found that in any or both of the first two months ofthe quarter, the tax liability net of available credit on the supplies made /received was higher than the amount paidin challan, then, no interest would be charged provided they deposit system calculated amount for each of the firsttwo months and discharge their entire liability for the quarter in the FORM GSTR-3B of the quarter by the due date.
In case such payment of tax by depositing the system calculated amount in FORM GST PMT-06 is not done by duedate, interest would be payable at the applicable rate, from the due date of furnishing FORM GST PMT-06 till the dateof making such payment.
Further, in case FORM GSTR-3B for the quarter is furnished beyond the due date, interest would be payable as perthe provisions of Section 50 of the CGST Act for the tax liability net of ITC.
Fixed Sum Method
07-01-2021 CA AANCHAL KAPOOR 36
A registered person, who has opted for the Scheme, had paid a total amount of Rs. 100/- in cash as tax liability in the previous quarter
of October to December. He opts to pay tax under fixed sum method.
He therefore pays Rs. 35/- each on 25th February and 25th March for discharging tax liability for the first two months of quarter viz.
January and February. In his return for the quarter, it is found that total liability for the quarter net of available credit was Rs. 125 but
he files the return on 30th April.
Interest would be payable at applicable rate on Rs. 55 [Rs. 125 – Rs. 70 (deposit made in cash ledger in M1 and M2)] for the period
between due date of quarterly GSTR 3B and 30th April
A registered person, who has opted for the Scheme, had paid a total amount of Rs. 100/- in cash as tax liability in the previous
quarter of October to December.
He opts to pay tax under fixed sum method. He therefore pays Rs. 35/- each on 25th February and 25th March for discharging tax
liability for the first two months of quarter viz. January and February.
In his return for the quarter, it is found that liability, based on the outward and inward supplies, for January was Rs. 40/- and for
February it was Rs. 42/-.
No interest would be payable for the lesser amount of tax (i.e. Rs. 5 and Rs. 7 respectively) discharged in these two months
provided that he discharges his entire liability for the quarter in the FORM GSTR-3B of the quarter by the due date.
EXAMPLES
07-01-2021 CA AANCHAL KAPOOR 37
Tax due in 1st
month
PMT-06 filed on 25th
Tax due for 2nd
month
PMT-06 filed on 25th
Total Liability in the quarter(Net ITC)
Difference GSTR 3B filed on due date
Interest Payable?
Remarks
35 Yes 35 Yes 150 80 Yes No -
35 No 35 Yes 150 80 Yes Yes Interest payable on 35 for no. of delay in filing 1st month PMT-06
35 Yes 35 No 150 80 Yes Yes Interest payable on 35 for no. of delay in filing 2nd month PMT-06
35 Yes 35 Yes 150 80 No Yes Interest payable on 80 for no. of days delay in filing 3B
35 No 35 No 150 80 No Yes Interest to be calculated separately for No. of days delay in 1st month PMT-06, 2nd month PMT-06 and GSTR 3B
Interest under Fixed Sum Method
07-01-2021 CA AANCHAL KAPOOR 38
Interest Applicability Self Assessment method
Interest amount would be payable as per the provision of Section 50 of the CGST Act for tax or any part thereof (net ofITC) which remains unpaid / paid beyond the due date for the first two months of the quarter.
Interest calculation for self assessment
Total liability for month1=100
ITC Available forMonth 1=50
Interest will becalculated on• Net of cash
liability ifnotdepositedby due date
OR• If any
amount isunpaid forany month
Net of cash =50
Total liability for month2=150
ITC Available forMonth 2=100
Net of cash =50
Total liability for month3=200
ITC Available forMonth 3=100
Net of cash =5007-01-2021 CA AANCHAL KAPOOR 39
Late Fee Under QRMP Scheme
Late Fee is applicable only for the delay in furnishing the GSTR 3B and GSTR 1
For Quarterly GSTR 3B filers, the late fee will apply only on the delay in furnishing theGSTR 3B for the quarter.
No late fee if the PMT-06 is filed beyond the due date during M1 and M2
07-01-2021 CA AANCHAL KAPOOR 41
Is scheme applicable GSTIN wise or PAN wise ?
➢ It is clarified that for calculating aggregate annual turnover, the turnover of PAN shall be considered. And while
opting for the scheme, taxpayer can opt in as per GSTIN wise.
Example:- If ABC Ltd, is having PAN based turnover of Rs. 3.67 Crore, then it can opt for the scheme. Now, it’s
having 3 GSTIN A, B, C, then GSTIN A can opt for the scheme. It is not compulsory that all GSTIN should opt for
the scheme.
Due Date for filling quarterly returns and payment of tax ?
Due date for filling GSTR 3B would be 22nd or 24th day of month succeeding such quarter. The due date for filling
GSTR 1 would be 13th day of month succeeding such quarter. Also, the tax shall be paid by 25th day of the
succeeding month due in each of the first two months.
07-01-2021 CA AANCHAL KAPOOR 42
Notification No. 82/2020-CT(R) Dated 10.11.2020
Effective from 01.01.2021
RULE 59
➢ Upload B2B invoices, the total value for such B2B invoices is capped to Rs. 50 lakhs per month usingINVOICE FURNISHING FACILITY.
➢ No need to report invoices again in GSTR-1 if already reported in IFF.➢ The invoices on IFF to be furnished from 1st day of next month till 13th day of next month.(1-13th)➢ B2B Invoices, Debit or Credit notes issued during month relating such Invoices.
FORM & MANNER OF FURNISHING DETAILS OF OUTWARD SUPPLIESGSTR 1
GSTR-1
Monthly Return
Aggregate turnover exceeding 5 crore rupees in the preceding FY or below 5 crore where QRMP is not opted
If registered person opted QRMP scheme
Quarterly Return
1st
month of Qtr
2nd
month of Qtr
Qtrending
may
GSTR-1B2C
Other B2B invoicesB2CL
Other Dr. & Cr. Notes
IFF
RULE 59
07-01-2021 CA AANCHAL KAPOOR 43
Quarterly Return
For January Upload invoices in IFF till 13th February
For February Upload invoices in IFF till 13th March
For March Upload invoices in GSTR 1 till 13th April
Example of Timelines for IFF
Invoices uploaded in
IFF will appear in
PART A of GSTR 2AForm GSTR-4AForm GSTR-6A
Effective from 01.01.2021
RULE 60 FORM & MANNER OF ASCERTAINING details of INWARD Supplies
Import of Goods by DTA from SEZ on Bill of Entry PART D OF GSTR 2A07-01-2021 CA AANCHAL KAPOOR 44
Effective from 01.01.2021
RULE 60FORM & MANNER OF ASCERTAINING details of INWARD Supplies
Form GSTR-2B notified Made available to RP EVERY MONTH
Day Immediately after Due Date of furnishing of IFF or
FORM GSTR 1 for the month whichever is later
1st& 2nd
month of Qtr
Qtrending
i.e 14th of Next Month
Day Immediately after Due Date of furnishing of FORM
GSTR 1 for the quarter
i.e 14th of Next Month after Qtrending
Details in Form GSTR-2B
For his Supplier with Monthly
Filling of GSTR1
Details uploaded from Day Immediately after Due Date of
furnishing last GSTR 1 till due date of furnishing GSTR1 for the month
e.g For January 2021 12th Jan ––––11th Feb
00:00 hours 23:59 hours
GSTR-5 NRTPGSTR-6 ISD
Details uploaded from Day Immediately after Due Date of
furnishing last GSTR 1 of quarter till due date of furnishing IFF
1stmonth of Qtr
2ndmonth of Qtr
3rd month of Qtr
e.g For January 2021 14th Jan ––––13th Feb
00:00 hours 23:59 hrs
Details uploaded from Day Immediately after Due Date of
furnishing last IFF till due date of furnishing IFF for the month
e.g For Feb, 2021 14th Feb ––––13th Mar
00:00 hours 23:59 hrs
Details uploaded from Day Immediately after Due Date of
furnishing last IFF till due date of furnishing GSTR 1 for the quarter
e.g For Mar, 2021 14th Mar ––––13th April
00:00 hours 23:59 hrs
For his Supplier with Quarterly Filling of
GSTR1
Import of Goods by DTA from SEZ on Bill of Entry07-01-2021 CA AANCHAL KAPOOR 45
Category oftaxpayers
GSTR-1 Invoice filingfacility
PMT-06 forMonth 1
PMT-06 for month2
GSTR 3B
Taxpayer who arerequired to filemonthly return:Taxpayers whoseaggregateturnover is overRs. 5 crore
11th of thefollowing month
NA NA NA 20th of thefollowing month
Taxpayer whohave opted forQRMP scheme
13th day of themonth followingthe quarter
1st to 13th day inMonth 1 & Month2
25th day of themonth followingmonth 1
25th day of themonth followingMonth 2
22nd or 24th day ofthe monthfollowing thequarter.
Return filing due dates w.e.f. 1st Jan 2021
07-01-2021 CA AANCHAL KAPOOR 46
Benefits of QRMP
Compliance burden of the taxpayer will be reduced significantly
Taxpayer needs to file only 4 GSTR-3B returns instead of 12 GSTR 3B returns in a year.
Taxpayer would be required to file only 4 GSTR -1 returns since invoice filing facility is providedunder the scheme
Pay the tax on monthly basis either by fixed sum method or self assessment method by generatingpre filled challan selecting “Monthly payment for quarterly taxpayers”
Furnish invoice details in IFF depending upon the requirement of their recipient, for first two monthsof the quarter. The remaining invoice details can be furnished in the quarterly GSTR-1
07-01-2021 CA AANCHAL KAPOOR 48
Important points regarding GSRT 1 ( Notified vide NN 94/2020 CT dt 22-12-2020
▪A registered person shall not be allowed to file GSTR-1 if he has not furnished the GSTR 3B for the
preceding 2 months.
▪ A registered person who opted for the QRMP scheme shall not be allowed to furnish the GSTR-1 or
use the IFF , if he has not furnished the GSTR 3B for the preceding tax period.
▪ A Registered person who is restricted from using the amount in the credit ledger in terms of Rule 86B
shall not be allowed to be allowed to file the GSTR-1 or use the IFF if he has not furnished the GSTR 3B
for the preceding tax period.
▪With effect from Jan 2021 , where the value of taxable supply in a month exceeds Rs. 50 Lakhs
(excluding exempt supply and zero-rated supply), the registered person shall be allowed to use the
credit ledger only for discharge of 99% of the tax liability – (New Rule 86B inserted)(subject to
Exceptions)07-01-2021 CA AANCHAL KAPOOR 52
Notification No. 74/2020 – Central Tax
Registered persons having aggregate turnover of up to 1.5 crore rupees in the preceding financial year or the currentfinancial year
Sl. No. Quarter for which details in FORM GSTR-1 are furnished
Time period for furnishing details in FORM GSTR-1
1 October, 2020 to December, 2020 13th January, 2021
2 January, 2021 to March, 2021 13th April, 2021
Registered persons having aggregate turnover of more than 1.5 crore rupees in the preceding financial year or the currentfinancial year
Notification No. 75/2020 – Central Tax
Sl. No. Quarter for which details in FORM GSTR-1 are furnished
Time period for furnishing details in FORM GSTR-1
1 October, 2020 to March 2021 11th day of the month succeeding such month
Suppressed by Not. 83/2020
07-01-2021 CA AANCHAL KAPOOR 54
In suppression of Not. 74/2020 and 75/2020. Time Limit for furnishing GSTR-1
Notification No. 83/2020 – Central Tax
Sl. No. Time period for furnishing details in FORM GSTR-1
1 Monthly 11th day of the month succeeding such month
2 Quarterly 13th day of the month succeeding such quarter
Effective from 01.01.2021N.N. 83/2020
07-01-2021 CA AANCHAL KAPOOR 55
N.N. 87/2020
Extension of time limit for furnishing the declaration in FORM GST ITC-04, in respect of goods dispatched to a job worker or received from a job worker, during the period from July, 2020 to September, 2020 till the 30th day of November, 2020. (Effective 25th October,2020)
N.N. 86/2020
Not. 76/2020 rescinded.(GSTR 3B dates for Oct,20-March,21)
N.N. 88/2020
E-invoicing is mandatory from 01.01.2021 for every taxpayer (other than SEZ unit) whose aggregate TO in any of the FY from 17-18 exceeds 100 Crores
N.N. 92/2020
The Central Government hereby appoints the 1st day of January, 2021, as the date on which the provisions of sections119, 120, 121, 122, 123, 124, 126, 127 and 131 of the said Act shall come into force.
N.N. 93/2020
Late fee payable for delay in furnishing of FORM GSTR-4 for the Financial Year 2019-20 under section 47 of the said Act,from the 1st day of November, 2020 till the 31st day of December, 2020 shall stand waived for the registered personwhose principal place of business is in the Union Territory of Ladakh.”.
N.N. 89/2020
Waiver of penalty payable by registered person u/s 125 for non compliance of N.N. 14/2020 till01.04.2021
N.N. 90/2020
8 digits HSN codes in tax invoice mandatory for some items
N.N. 91/2020
Anti- Profiteering Action by department time extended till March 2021
07-01-2021 CA AANCHAL KAPOOR 56
Notification No. 17/2020 dated 23.03.2020
The class of persons who shall be exempted from Aadhaar authentication has been notifiedAny person who is not a citizen of India or belong to a class of persons, except the persons mentioned below, are not required to get an aadhaar authentication done, from 1st April 2020:1. Individual2. Authorised signatory of all types3. Managing and Authorised partner, and4. Karta of an Hindu undivided family.
Notification No. 18/2020 dated 23.03.2020
The effective date for Aadhaar authentication before obtaining GST registration is notified.The effective date for Aadhaar authentication before obtaining GST registration is notified------------- 01-04-2020.
Notification No. 19/2020 dated 23.03.2020
The class of persons, other than individuals who shall undergo authentication of Aadhaar number to be eligible forregistration, has been notified.The following persons shall undergo the aadhaar authentication from 1st April 2020:1. Authorised signatory of all types,2. Managing and Authorised partners of a partnership firm, and3. Karta of an Hindu undivided family
07-01-2021 CA AANCHAL KAPOOR 61
Amendment in Rule 8(4A)
Every application made under rule (4) shall be followed by—
(a) biometric-based Aadhaar authentication and taking photograph, unless exempted under sub-section (6D) of section25, if he has opted for authentication of Aadhaar number; or
(a) taking biometric information, photograph and verification of such other KYC documents, as notified, unless theapplicant is exempted under sub-section (6D) of section 25, if he has opted not to get Aadhaar authentication done,
of the applicant where the applicant is an individual or of such individuals in relation to the applicant as notified undersub-section (6C) of section 25 where the applicant is not an individual, along with the verification of the original copy ofthe documents uploaded with the application in FORM GST REG-01 at one of the Facilitation Centres notified by theCommissioner for the purpose of this sub-rule and the application shall be deemed to be complete only after completionof the process laid down under this sub-rule.”.
N.N. 94/2020-CT Dated 22-12-2020
Date to be notified
07-01-2021 CA AANCHAL KAPOOR 62
Aadhar Authentication N.N. 62/2020
Rule 9:- (Verification of the application and approval)Cases of Deemed Registration:-Rule9(5) Proper officer fails to take any action within a period of :-
person successfully undergoesauthentication of Aadhaar number
three working days from the date of submission of the application
fails to undergo authentication of Aadhaarnumber as specified in sub-rule (4A) of rule 8 twenty one days from the date of submission of the application
person does not opt forauthentication of Aadhaar number twenty one days from the date of submission of the application
within a period of seven working days from the date of the receipt of the clarification, information or documents furnished by theapplicant under sub-rule (2),
Rule 25 substituted with following:-“Physical verification of business premises in certain cases.-Where the proper officer is satisfied that the physicalverification of the place of business of a person is required due to failure of Aadhaar authentication or due to not optingfor Aadhaar authentication before the grant of registration, or due to any other reason after the grant of registration, hemay get such verification of the place of business, in the presence of the said person, done and the verification reportalong with the other documents, including photographs, shall be uploaded in FORM GST REG-30 on the common portalwithin a period of fifteen working days following the date of such verification.”.
UPTO 22.12.2020
07-01-2021 CA AANCHAL KAPOOR 63
person successfully undergoesauthentication of Aadhaar number
three working days from the date of submission of the application
fails to undergo authentication of Aadhaarnumber as specified in sub-rule (4A) of rule 8 twenty one days from the date of submission of the application
person does not opt forauthentication of Aadhaar number
Amendment in Rule 9
Verification of the application and approval
07-01-2021 CA AANCHAL KAPOOR 64
w.e.f 22-12-2020
N.N. 94/2020-CT Dated 22-12-2020
Rule 9:- (Verification of the application and approval)Cases of Deemed Registration:-Rule9(5) Proper officer fails to take any action within a period of :-
Thirty days from the date of submission of the application*
person successfully undergoesauthentication of Aadhaar number
Seven working days from the date of submission of the application
fails to undergo authentication of Aadhaarnumber as specified in sub-rule (4A) of rule 8 Thirty days from the date of submission of the application*
person does not opt forauthentication of Aadhaar number
within a period of seven working days from the date of the receipt of the clarification, information or documents furnished by theapplicant under sub-rule (2),
*PO not below rank of AC authorized by Commissioner may carry the Physical Verification of Place of Business, inpresence of said person.
*Notice in Form GST REG-03 may be issued upto 30 days from date of submission of application.
N.N. 94/2020-CT Dated 22-12-2020
The registration granted to a person is liable to be cancelled, if the said person:-
a) does not conduct any business from the declared place of business; or
b) issues invoice or bill without supply of goods or services 2[or both] in violation of the provisions of the Act, or the
rules made thereunder; or
c) violates the provisions of section 171 of the Act or the rules made thereunder.
d) violates the provision of rule 10A
e) avails input tax credit in violation of the provisions of section 16 of the Act or the rules made thereunder; or
f) furnishes the details of outward supplies in FORM GSTR-1 under section 37 for one or more tax periods which is in
excess of the outward supplies declared by him in his valid return under section 39 for the said tax periods; or
g) violates the provision of rule 86B.
Amendment in Rule 21
Cancellation of registration
07-01-2021 CA AANCHAL KAPOOR 65
GSTR1 > GSTR 3B
Anti Prof.
Bank a/c details in 45 days
Amendment in Rule 21A
1. Where a registered person has applied for cancellation of registration under rule 20, the registration shall be deemed tobe suspended from the date of submission of the application or the date from which the cancellation is sought,whichever is later, pending the completion of proceedings for cancellation of registration under rule 22.
2. Where the proper officer has reasons to believe that the registration of a person is liable to be cancelled under section29 or under rule 21, he may 2[***], suspend the registration of such person with effect from a date to be determined byhim, pending the completion of the proceedings for cancellation of registration under rule 22.
(2A) Where, a comparison of the returns furnished by a registered person under section 39 with
a) the details of outward supplies furnished in FORM GSTR-1 ; or
b) the details of inward supplies derived based on the details of outward supplies furnished by his suppliers in their FORM
GSTR-1,
or such other analysis, as may be carried out on the recommendations of the Council, show that there are significant
differences or anomalies indicating contravention of the provisions of the Act or the rules made thereunder, leading to
cancellation of registration of the said person, his registration shall be suspended and the said person shall be intimated
in FORM GST REG-31 , electronically, on the common portal, or by sending a communication to his e-mail address
provided at the time of registration or as amended from time to time, highlighting the said differences and anomalies and
asking him to explain, within a period of thirty days, as to why his registration shall not be cancelled.]
(3) A registered person, whose registration has been suspended under sub-rule (1) or sub-rule (2), 3[or sub-rule (2A)] shall notmake any taxable supply during the period of suspension and shall not be required to furnish any return under section 39.
Suspension of registration.
07-01-2021 CA AANCHAL KAPOOR 66
OBH removed
GSTR 2A/2B
GSTR 3B
Rule 36(4):- Input tax credit to be availed by a registered person in respect of invoices or debit notes, the details of
which have not been furnished by the suppliers under sub-section (1) of section 37, in FORM GSTR-1 or using the
invoice furnishing facility shall not exceed 5 per cent of the eligible credit available in respect of invoices or
debit notes the details of which have been furnished by the suppliers under sub-section (1) of section 37 in FORM GSTR-
1 or using the invoice furnishing facility
Rule 36(4) amended (effective from January 1, 2021)
Reduction in ITC entitlement for invoices not furnished by supplier from 10% to 5%
07-01-2021 CA AANCHAL KAPOOR 67
Explanation.-For the purposes of this sub-rule, the expression "shall not make any taxable supply" shall mean that the registered personshall not issue a tax invoice and, accordingly, not charge tax on supplies made by him during the period of suspension4) The suspension of registration under sub-rule (1) or sub-rule (2) 3[or sub-rule (2A)] shall be deemed to be revoked upon completion of theproceedings by the proper officer under rule 22 and such revocation shall be effective from the date on which the suspension had come intoeffect:]Provided that the suspension of registration under this rule may be revoked by the proper officer, anytime during the pendency of theproceedings for cancellation, if he deems fit.]5) Where any order having the effect of revocation of suspension of registration has been passed, the provisions of clause (a) of sub-section(3) of section 31 and section 40 in respect of the supplies made during the period of suspension and the procedure specified therein shallapply.]
Circular No. 145/01/2021-GST
SOP for implementation of the provision of suspension of registrations under sub-rule (2A) of rule 21A of CGST Rules, 2017
Return furnishedu/s 39 Compared with
the details of outward supplies furnishedin FORM GSTR-1
the details of inward supplies derivedbased on the details of outward suppliesfurnished by his suppliers in their FORMGSTR-1
or
Significant differencesor anomaliesindicatingcontravention of theprovisions of the Actor the rules
leading to cancellation ofregistration of the said person
Registration shall besuspended and the saidperson shall be
Intimation inFORM GST REG-31
electronically, onthe common portal
by sending acommunication tohis e-mail address
highlighting the said differences and anomaliesand asking him to explain, within a period ofthirty days, as to why his registration shall notbe cancelled.”
Post issuance of FORM GST REG-31 via email, the list
of such taxpayers would be sent to the concerned
Nodal officers of the CBIC/ States. Upon receipt of
reply from the said person or on expiry of thirty days
(reply period), a task would be created in the
dashboard of the concerned proper officer under
“Suo moto cancellation proceeding”.
Till the time functionality for FORM REG-31 is made available on portal, such notice/intimation shall be made availableto the taxpayer on their dashboard on common portal in FORM GST REG-17
The taxpayers will be able to view the notice in the “View/Notice and Order” tab post login.
Taxpayer whoseregistrationsuspended
furnish reply to the jurisdictionaltax officer within thirty daysfrom the receipt of such notice /intimation, explaining thediscrepancies/anomalies
reply to the jurisdictional officer against the noticefor cancellation of registration sent to them, inFORM GST REG-18 online through Common Portalwithing the time limit of thirty days from thereceipt of notice/ intimation.
In case the intimation for suspension and notice for cancellationof registration is issued on ground of non -filing of returns, thesaid person may file all the due returns and submit the response.Similarly, in other scenarios as specified under FORM GST REG-31,they may meet the requirements and submit the reply.
post examination of the response received from the said person, may pass an order either for dropping the proceedings forsuspension/ cancellation of registration in FORM GST REG-20 or for cancellation of registration in FORM GST REG-19. Basedon the action taken by the proper officer, the GSTIN status would be changed to “Active” or “Cancelled Suo-moto” as the casemaybe.
N.N. 94/2020-CT Dated 22-12-2020
GSTR-1 to be blocked in case of non filing of GSTR 3B
✓ Where a taxpayer fails to file GSTR 3B for two preceeding months, his GSTR 1 shall now be blocked.
✓ Similarly, for quarterly return filers, the taxpayer failing to file GSTR 3B for the preceding quarter shall not be permitted to file GSTR
1 of subsequent quarter or IFF.
✓ Persons covered by provisions of Rule 86B, fails to file GSTR 3B for preceeding Tax Period(M/Q), his GSTR 1 shall now be blocked
(Earlier non filing of GSTR 3B used to result in blocking of E-way Bill facility but from now on it shall also result in blocking of GSTR 1 of the taxpayer.)
Rule 59
07-01-2021 CA AANCHAL KAPOOR 70
Not. 94/2020 wrongly mentioned sub rule (5) of 59
Anomaly removed by not. 01/2021 by making it Rule
59(6)
Rule 86B
Notwithstanding anything contained in these rules, the registered person shall not use the amount available in electronic creditledger to discharge his liability towards output tax in excess of ninety-nine per cent. of such tax liability, in cases where thevalue of taxable supply other than exempt supply and zero-rated supply, in a month exceeds fifty lakh rupees:
Provided that the said restriction shall not apply where –a) the said person or the proprietor or karta or the managing director or any of its two partners, whole-time Directors, Members
of Managing Committee of Associations or Board of Trustees, as the case may be, have paid more than one lakh rupees asincome tax under the Income-tax Act, 1961(43 of 1961) in each of the last two financial years for which the time limit to filereturn of income under subsection (1) of section 139 of the said Act has expired; or
b) the registered person has received a refund amount of more than one lakh rupees in the preceding financial year onaccount of unutilised input tax credit under clause (i) of first proviso of sub-section (3) of section 54; or
c) the registered person has received a refund amount of more than one lakh rupees in the preceding financial year on accountof unutilised input tax credit under clause (ii) of first proviso of sub-section (3) of section 54; or
d) the registered person has discharged his liability towards output tax through the electronic cash ledger for an amountwhich is in excess of 1% of the total output tax liability, applied cumulatively, upto the said month in the current financialyear; or
e) the registered person is –(i) Government Department; or(ii) a Public Sector Undertaking; or(iii) a local authority;or ((iv) .statutory body:
Provided further that the Commissioner or an officer authorised by him in this behalf may remove the said restriction after suchverifications and such safeguards as he may deem fit.”.
Restrictions on use of amount available in electronic credit ledger
07-01-2021 CA AANCHAL KAPOOR 71
01.01.2021
07-01-2021
CA AANCHAL KAPOOR 72
Registered Person
Value of taxablesupply in a monthexceeds 50 Lacs
Exempt Supply
Zero Rated Supply This provision is N.A
(can use 100% credit)
Person
proprietorKarta
Any of its twopartnerswhole-timeDirectors, Membersof ManagingCommittee ofAssociations orBoard of Trustees
Paid more than 1lakh as income taxin each of last twoF.Y.
Claimed Refund>100000 inpreceding F.Y. onaccount of unutilized ITC ofexports
Claimed Refund>100000 inpreceding F.Y. onaccount of unutilized ITC ofinverted dutystructure
Output tax paidthrough cashledger > 1% of totaloutput, appliedcumulatively, uptothe said month incurrent F.Y.
Registered person isI. Government
Department; orII. a Public Sector
Undertaking; orIII. a local authority;orIV. a statutory body:MAT and TDS also
considered as IncomeTax (not necessarilyCash Payment)
Provided further that the Commissioner or an officer authorised by him in this behalf may remove the said restriction aftersuch verifications and such safeguards as he may deem fit.”.
99% of such tax liability
Shall not use the
amount available inelectronic credit ledger
i.e Max 99% of Input can be used
to discharge output liability
LEGAL PROVISION
Registered Person Exempt Turnover Export turnover Taxable turnover Rule 86B applicable
February,2021 1 crore 2 crore 45 lakhs No (Rs. 45 lakhs)
March,2021 40 lakhs 15 lakhs 1 crore Yes (Rs. 1 crore)
March 2021
Taxable Sale = 1 Crore Monthly turnover > 50 lakhs Tax @ 5% = 500000 ITC = 800000
Old New
Output 500000 Output 500000
ITC utilized 500000 ITC Utilized (99 % of 500000) 495000
Tax payable 0.00 Tax payable (1%) 5000
Exceptions:- 100 % ITC (Old Rule)
F.Y. 19-20, F.Y. 18-19- 139(1) time expired, Income Tax paid> 1000001
April, 2020- FEb, 2021
Output ITC Cash Ledger
10 Cr 99 Lacs 100000
10Cr 98.5 Lacs 150000
New Rule
Old Rule
3
2
Refund > 1 lakh in F.Y 2019-20
Exports Inverted Duty structure
What if Export with Payment of Taxes ?
or
CASE STUDY
Illustration 1
Particulars CGST SGST IGST Total
Output Turnover 5000000 5000000 3000000 1,30,00,000
Output Tax @18% 900000 900000 540000 23,40,000
Input Tax 960000 960000 500000 24,20,000
Minimum Tax payable as per Rule 86B 9000 9000 5400 23,400
Particulars CGST SGST IGST Total
Output Tax 900000 900000 540000 23,40,000
Input Tax 820000 1000000 540000 2360000
Minimum Tax payable as per Rule 86B 9000 9000 5400 23400
Payment if 86B not there 80000 0 0 80000
Tax payable as per 86B 80000-5400= 74600 9000 (not adjustable with CGST)
5400 paid in IGST adjusted with CGST.
89000
Illustration 2
Particulars CGST SGST IGST Total
Output Turnover 5000000 5000000 3000000 1,30,00,000
Output Tax @18% 900000 900000 540000 23,40,000
Input Tax 820000 820000 540000 21,80,000
Minimum Tax payable as per Rule 86B 9000 9000 5400 23,400
Minimum tax otherwise payable through cash ledger without 86B 80000 80000 - 1,60,000
By paying Rs. 5400 in cash, IGST ITC of 5400 adjusted with C & S, so now Net Payable 77300 77300 5400 1,60,000
Illustration 3
Rule 138 amended (effective from
January 1, 2021)Validity of e-way bill narrowed by increasing distance from 100 km. to 200 km. per day
E-way bill will now be valid for 24 hours for every 200 km of travel, as against 100 km earlier, in cases otherthan Over Dimensional Cargo or multimodal shipment.
N.N. 94/2020-CT Dated 22-12-2020
07-01-2021 CA AANCHAL KAPOOR 75
Person shall not be allowed to furnish information in PART A of FORM GST EWB-01 in respect of a registeredperson, whether as a supplier or a recipient, who• being a person, whose registration has been suspended under the provisions of sub-rule (1) or sub-rule (2) or
sub-rule (2A) of rule 21A:]
Rule 138E amended Restriction on furnishing of information in Part A of FORM GST EWB-01.
Delinking of Debit Notes
Document
Type
Document date Due date for availing credit
Before Amendment
Debit note 15-08-2021
(Linked to Invoice dated 01-
03-2021)
Return for the month of sept. 2021
Debit note 15-11-2021
(Linked to Invoice dated 01-
03-2021)
Return for the month of sept. 2021.
The credit was not getting availed for Debit notes issued after 6 months from end of
Financial Year to which Invoice pertains to.
After amendment
Debit note 15-08-2021
(Linked to Invoice dated 01-
03-2021)
Invoice Linkage became
irrelevant
Return for the month of sept. 2022
Debit note 15-11-2021
(Linked to Invoice dated 01-
03-2021)
Invoice Linkage became
irrelevant
Return for the month of sept. 2022.
The credit which was earlier not getting availed for Debit notes issued after 6 months
from end of Financial Year to which Invoice pertains to will now be available.
FA,2020
What is QRMP scheme? What are its benefit?
➢ Quarterly Return, Monthly Payment of Taxes (QRMP) Scheme is a scheme to simplify compliance for small taxpayers.➢ Under this scheme, taxpayers having an aggregate turnover at PAN level up to Rs. 5 Crore can opt for quarterly GSTR-1 and
GSTR-3B filing. Payment can be made in the first two months by a simple challan in FORM GST PMT-06. For the ease oftaxpayers, system has assigned quarterly frequency to small taxpayers automatically.
Why have I been assigned quarterly filing without opting for the same?
➢ Taxpayers eligible for the simplified compliance scheme were assigned quarterly frequency by the GST system. Alltaxpayers were informed regarding the frequency assigned to them by e-mail and SMS.
Why have I been assigned quarterly frequency by system even when my aggregate turnover on PAN is greater thanRs. 5 crore?
➢ For the purpose of determining the eligibility for QRMP, the turnover was determined on the basis of the valuesdeclared by taxpayers in Table-3.1 of GSTR-3B (except inward supplies attracting reverse charge) for the FinancialYear 2019-20. If a component of the turnover, like exempted or non-GST turnover, was not declared by a taxpayer inGSTR-3B or was declared in next financial year, then the turnover computed by the system for such taxpayers couldbe less than Rs. 5 crore. Such taxpayers may have been assigned to QRMP on the basis of values declared by them inGSTR-3B. Such taxpayers are advised to opt-out of scheme for quarter Apr-Jun’21 by 30 th April 2021.
Why have I been assigned monthly frequency by system even when my aggregate turnover on PAN is upto Rs. 5crore?
At the time of assigning the frequency by the system, system considered the aggregate turnover of the taxpayer and thefiling status of FORM GSTR-3B for the month of October 2020. If the said GSTR3B was not filed till 30th November 2020,the taxpayer were assigned to monthly frequency. The system allows the taxpayer to opt for QRMP scheme only if the lastapplicable return in FORM GSTR-3B, whose due date is over, is filed.
Illustration : If the taxpayer is trying to opt for QRMP Scheme on 25th Feb’21, from Quarter Apr-Jun’21 onwards then itwill be allowed only if the return in form GSTR-3B is filed for the month Jan’21. If the taxpayer is trying to opt for QRMPScheme on 19th Feb’21, from Quarter Apr-Jun’21 onwards then it will be allowed only if the return in form GSTR-3B isfiled for the month Dec’20.
I want to opt-out of QRMP scheme and become monthly filer. Why the portal is not allowing me to do same for thequarter Jan-Mar, 2021?
The last date to choose or change the filing frequency for the quarter of January to March 2021 was 31st January, 2021.After 31st January 2021, the filing frequency cannot be changed for the quarter January to March 2021.
However, for the quarter of April to June 2021, taxpayers may change their filing frequency from quarterly to monthlyfrom 1st February, 2021 to 30 th April, 2021. It may be noted that profile selection is not a recurring requirement everyquarter. Once a frequency has been opted for, it is applicable for all future periods unless changed further.
What is IFF? Is it another compliance requirement?
Invoice Furnishing Facility (IFF) is an optional facility made available as per Rule-59(2) of the CGST Rules, 2017. This isprovided for those quarterly taxpayers who want to pass on input tax credit (ITC) to their recipients (buyers/customers) infirst two months of a quarter. Since IFF is an optional facility, it poses no additional compliance burden. It is a facility forthose quarterly filers who intend to pass ITC to their recipients in first two months of the quarter. It may be noted thatsince IFF is an optional facility, IFF for a month will expire after the due date of 13th of next month, and cannot be filedafter this date.
Is filing IFF mandatorily or optional?
Invoice Furnishing Facility (IFF) is an optional facility to those taxpayers who want to pass on input tax credit (ITC) totheir recipients (buyers/customers) in first two months of a quarter. Those taxpayers who do not have to pass credit totheir recipients need not file IFF in the first two months of the quarter. They may declare their outward supplies in thequarterly FORM GSTR-1. It may be noted that since IFF is an optional facility, IFF for a month will expire after the duedate of 13th of next month, and cannot be filed after this date.
How do I make payment of my liability in first two months of the quarter?
In first two months of the quarter, payment of liability can be made by either of the following two methods:a. Fixed Sum Method: Portal will generate a pre-filled challan in Form GST PMT-06. The system generated pre-filled
challan in this case is commonly also known as 35% challan.b. Self-Assessment Method: The actual tax due is to be paid through challan, in Form GST PMT-06, by considering the tax
liability on inward and outward supplies and the input tax credit available for the period as per law.The due date for making payment by challan is 25th of the next month.
What is fixed sum method of payment?
In fixed sum method, the taxpayer is required to pay a system generated challan in the first two months of a quarter. Thesystem generated pre-filled challan in this case is commonly also known as 35% challan. If fixed sum method is opted forby the taxpayer & there is no ITC to be passed in that month, then except for paying system generated challan, no othercompliance requirement is there in the first two months of the quarter.
How is the 35% challan computed under the fixed sum method?
Under the fixed sum method, depending on the filing frequency in the previous quarter, the 35% challan is calculated by
either of the following methods:
Method (a) : An amount which is equivalent to the amount paid as tax from electronic cash ledger in their GSTR-3B return
for the last month of the immediately preceding quarter, where the GSTR-3B return was furnished on monthly basis.
OR
Method (b) : 35% of amount paid as tax from electronic cash ledger in their return for the preceding quarter, where the
GSTR-3B return was furnished on quarterly basis; or
It may be noted that since QRMP scheme is introduced in January 2021, all taxpayers were monthly filers in December
2020. Hence, the 35% challan will be populated as per method (a) for the quarter of January to March 2021 for quarterly
filers.
How do I declare B2C supplies in IFF for first two month of quarter if I have opted for QRMP?
Illustration:
Method (a) : Taxpayer paid liability by cash amounting to Rs. 5500/- [IGST: Rs. 2,000/-, CGST: Rs. 1,000/-, SGST: Rs. 2,500/-
] in monthly GSTR-3B for December 2020. The 35% challan generated as per the fixed sum method for January to March
2021 quarter will be of Rs. 5,500/- with the same head-wise break-up.
Method (b) : Taxpayer paid liability by cash amounting to Rs. 7000/- [IGST: Rs. 1,000/-, CGST: Rs. 2,000/-, SGST: Rs. 4,000/-
] in quarterly GSTR-3B for January to March 2021. The 35% challan generated as per the fixed sum method for April to
June 2021 quarter will be of Rs. 2,450/- [IGST: Rs. 350/-, CGST: Rs. 700/-, SGST: Rs. 1,400/-].
Supplies made to unregistered persons (also called B2C supplies) are not required to be declared in IFF. These may bedeclared in FORM GSTR-1 for the quarter
Taxpayers will be provided with a draft GSTR-3B, which will contain the details of the liability to be paid by taxpayers in
the quarterly GSTR-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 autopopulated in quarterly GSTR-3B.
How will I reconcile the values declared in IFF & GSTR-1 with quarterly GSTR-3B?
How do I claim ITC for the first two months of the quarter?
In first two months of the quarter, no declaration pertaining to ITC is required to be made. The available ITC for the entire
quarter will be made available by the system in quarterly FORM GSTR-2B. This quarterly facility will be in addition to the
FORM GSTR-2B being made available on monthly basis, which can still be used for doing self-assessment.
How do I again become a Monthly filer?
Filing frequency either monthly or quarterly can be selected as per timelines mentioned in below table.Kindly navigate : Services > Returns > Opt-in for Quarterly Return
Effective Quarter (1)
Period during which filing frequency can be selected (2)
Last date for selecting the filing frequency (3)
January–February– March# 1st November to 31st January 31st January
April – May – June 1st February to 30th April 30th April
July – August – September 1st May to 31st July 31st July
October – November – December 1st August to 31st October 31st October
# For the quarter of January to March 2021, this option was available from 5th December 2020 to 31st January2021.
How do I again become a Monthly filer?
Filing frequency either monthly or quarterly can be selected as per timelines mentioned in below table.Kindly navigate : Services > Returns > Opt-in for Quarterly Return
Effective Quarter (1)
Period during which filing frequency can be selected (2)
Last date for selecting the filing frequency (3)
January–February– March# 1st November to 31st January 31st January
April – May – June 1st February to 30th April 30th April
July – August – September 1st May to 31st July 31st July
October – November – December 1st August to 31st October 31st October
# For the quarter of January to March 2021, this option was available from 5th December 2020 to 31st January2021.
E- InvoicingNotification No. Particulars
N. N. 68/2019-CT Rule 48(4) :- E- Invoice introduced
N.N. 69/2019-CT Seeks to notify the common portal for the purpose of e-invoice.
N. N. 70/2019-CT Notify the class of registered person required to issue e-invoice.
N.N. 72/2019-CT Seeks to notify the class of registered person required to issue invoice having QR Code.
N.N. 02/2020-CT Form INV-01 substituted
N.N. 13/2020-CT Seeks to exempt certain class of registered persons from issuing e-invoices and the date for implementation of e-invoicing extended to 01.10.2020
N.N. 14/2020-CT Seeks to exempt certain class of registered persons capturing dynamic QR code and the date for implementation of QR Code to be extended to 01.10.2020.
N. N. 61/2020-CT Seeks to amend Notification no. 13/2020-Central Tax in order to amend the class of registered persons for the purpose of e-invoice.
N.N. 70/2020-CT Seeks to amend notification no. 13/2020-Central Tax dt. 21.03.2020.
N.N. 71/2020-CT Seeks to amend notification 14/2020- Central Tax to extend the date of implementation of the Dynamic QR Code for B2C invoices till 01.12.2020.
N.N. 73/2020-CT Seeks to notify a special procedure for taxpayers for issuance of e-Invoices in the period 01.10.2020 - 31.10.2020.
N.N. 88/2020-CT Seeks to implement e-invoicing for the taxpayers having aggregate turnover exceeding Rs. 100 Cr from 01st January 2021.
N.N. 89/2020-CT Seeks to waive penalty payable for noncompliance of the provisions of notification No.14/2020 – Central Tax, dated the 21st March, 2020.
E-invoicing under GST
Legal Provisions
N. N. 68/2019-CT Rule 48(4)
The invoice shall be prepared by such class of registered persons as may be notified bythe Government, on the recommendations of the Council, by including such particularscontained in FORM GST INV-01 after obtaining an Invoice Reference Number byuploading information contained therein on the Common Goods and Services TaxElectronic Portal in such manner and subject to such conditions and restrictions as maybe specified in the notification.
(5) Every invoice issued by a person to whom sub-rule (4) applies in any manner otherthan the manner specified in the said sub-rule shall not be treated as an invoice.
N. N. 61/2020-CT Registered person, whose aggregate turnover in a financial year exceeds 500 Crore w.e.f
01.10.2020
N. N. 70/2020-CTAny preceding financial year from2017-18 onwards.
N. N. 88/2020-CT Registered person, whose aggregate turnover in a financial year exceeds 100 Crore w.e.f
01.01.2021
N.N. 69/2019-CT:- Common portal for the purpose of e-invoice
(i) www.einvoice1.gst.gov.in;
(ii) www.einvoice2.gst.gov.in;
(iii) www.einvoice3.gst.gov.in;
(iv) www.einvoice4.gst.gov.in;
(v) www.einvoice5.gst.gov.in;
(vi) www.einvoice6.gst.gov.in;
(vii) www.einvoice7.gst.gov.in;
(viii)www.einvoice8.gst.gov.in;
(ix) www.einvoice9.gst.gov.in;
(x) www.einvoice10.gst.gov.in
Effective from 01.01.2020
• E Invoicing aggregate Turnover > 500 crores ----------------------------------------------------------------------------------------------01.10.2020
• Invoice Reference Number (IRN) for such invoice by uploading specified particulars
in FORM GST INV-01 within 30 days from the date of such invoice--------------------------------------------------------01.10.2020 to 31.10.2020
(N.N. 73/2020-CT)
• E Invoicing Aggregate Turnover > 100 crores ------------------------------------01.01.2021
N.N. 73/2020-CT:- Seeks to notify a special procedure for taxpayers for issuance of e-Invoices in the period 01.10.2020 - 31.10.2020.
E- Invoice Process
Taxpayer
Upload
Invoice Details
Government Invoice RegistrationPortal (IRP) managed by GSTNlaunched by the NationalInformatics Centreat einvoice1.gst.gov.in.
GSTR-1 No Manual filing
E-way Bill
Real Time Basis
❑ Post successful authentication, a unique Invoice ReferenceNumber (IRN) is generated for each invoice.
❑ Each invoice is digitally signed and added with QR code.
Exemption from E- Invoicing
An Insurer, BankingCompany, orFinancial Institutionincluding NBFC.
Goods
Transport
Agency (GTA).
Passenger
Transport Service.
Admission to the
exhibition of
Cinematograph
Films in Multiplex
Screens ie. PVR.
SEZ UNIT (SEZ
DEVELOPER is not
exempted)
N.N. 13/2020-CT
N.N. 61/2020-CT
E- Invoice Process
Documents Covered by E- Invoice System
Invoice Credit Note Debit Note
‘e-invoicing’ is not generation of invoice by a Government portal. Taxpayers will continue to create their GST invoices on their own
Accounting/Billing/ERP Systems.
These invoices will now be reported to ‘Invoice Registration Portal (IRP)’.
On reporting, IRP will generate a unique ‘Invoice Reference Number (IRN)’, digitally sign it and return the e-invoice. A GST
invoice will be valid only with a valid IRN.
IRP will also generate a QR code containing the unique IRN along with certain other key particulars. The QR code (which can
be printed on invoice) enables offline verification of the fact whether the e-invoice has been reported on the IRP or not (using
Mobile App etc.)
E- Invoicing Process
Supplier with PAN basedaggregate turnover inpreceding F.Y. > 100 Crore
Buyer
Issues Invoice with QR Code
IRPInvoice registration portal
• Performs prescribed validations• No storage/ archival
IRP 2 will be added soon
E-way bill System(Auto population of E-wayBill (Where required)
IRN Lookup System(To Check and rule outexistence of some IRN)
Auto population of invoicedetails into GSTR-1/2A
Search IRN facility on GSTPortal (To verifyauthenticity of IRN)
Modes of generation of E- Invoice
API Based (Integrationwith tax payer systemdirectly)(e.g Tally)
API Based (Integration with tax payer system throughGSP/ASP) (e.g an offline utility like spreadsheetwhere taxpayers could fill out their invoices and thenupload on GST portal.) (Approved GSP examples- TCSltd., Tally solutions Pvt. Ltd., Taxmann PubliactionsPvt. Ltd. Etc)
‘Free Offline Utility (Bulkgeneration Tool’,downloadable from IRP)
Web Based/ mobile based modes will also be provided in future.
E-invoice – Detailed Work flow
Seller
• Uploads E- invoice
(Containing GSTIN,
Invoice Number, Date,
Value etc.
• Receives digitally signed
JSON of E- Invoice that
contains the QR Code.
• Sellers GSTR-1 gets
updated with liability
entered in invoice.
Invoice Registration Portal
• Signs the invoice.
• Adds a QR to the JSON.
• Sends back signed JSON
to buyer.
• Sends the invoice to
GST System.
GST System
• Updates outward and
inward supplies for
buyer and seller.
• Now has unique invoice
with unique number.
Buyer
• Buyer can view the
ITC related to the
invoice in GSTR-2A.
B2B APIs
APIs
Seller
Seller to have JSONpreparing utility from excel,word, ERP AccountingSoftware, Mobile app etc.
1
Prepare E- invoice asper schema havingmandatory (GSTIN,Invoice No. Date,Value etc.) andoptional fields
2
Uploads JSON of E- Invoice to IRP
Receives the digitallysigned JSON, of the E-Invoice that containsthe QR Code
Invoice Registration Portal
3
B2
B A
PIs/ D
irect Interactio
ns o
n IR
P
JSON pushed to IRP
IRP have the facility to:-• Accept JSON through
APIs• Accept JSON- direct
upload
Returns digitallysigned JSON to theseller with the QRcode included in it.
4
5
• Generates IRN• Does de-duplication
check with GST system• Signs JSON with digital
signatures of IRP.• Adds QR code to JSON.
6a
• Sendsauthenticatedpayload to GSTSystem.
• Sends to E- waySystem.
Interaction between the business (supplier) and the Invoice Registration Portal (IRP).
Invoice Registration Portal
3
JSON pushed to IRP
IRP have the facility to:-• Accept JSON through
APIs• Accept JSON- direct
upload
Returns digitallysigned JSON to theseller with the QRcode included in it.
4
5
• Generates IRN• Does de-duplication
check with GST system• Signs JSON with digital
signatures of IRP.• Adds QR code to JSON.
6a
• Sendsauthenticatedpayload to GSTSystem.
• Sends to E- waySystem.
Interaction between the IRP and the GST/E-Way Bill Systems and the Buyer.
GST System
B2
B A
PIs/ D
irect Interactio
ns o
n IR
P
• Invoice informationstored in GST invoiceregistry.
• De- duplicationchecked.
4a
6b
• GST system now hasunique invoice withunique number.
• GSTR-1 of sellerupdated.
• GSTR-2A of buyerupdated.
Buyer
• Buyer can use the QRcode to verify theinvoice.
• Buyer can view the ITCrelated to the invoicein his GSTR-2A
• E-way bill system willcreate the E-way Bill.
6c
Cancellation/Amendment of Reported Invoice:
The seller can initiate cancellation of IRN of the e-invoice already reported, if that invoice is required to be cancelled by him/her. The
cancellation of an invoice will be done as per procedure given under accounting standards. The cancellation will be allowed within
specified time after generation of IRN.
The cancellation of e-invoice will be done by using the ‘Cancel IRN’ API (published on the e-invoice sandbox portal). The API will be a
POST API and will require the IRN that is to be cancelled as the key parameter of the payload.
The invoice number of cancelled invoice can’t be used again.
Amendment of e-invoice already uploaded on IRP will be done only on GST portal.
Any amended e-invoice, if reported to IRP, will get rejected as its IRN (unique hash) will already be existing in the IRP system. Hence,
amendment of invoices will not be possible through the IRP.
Advantages
Elimination of Fake invoices
One Time reporting
Helpful in GSTReturn preparation
Helpful in E- WayBill preparation
Trigger Point of Entire Automated Process
For which businesses, e-invoicing is mandatory ?
For Registered persons whose aggregate turnover (based on PAN) in any preceding financial year from 2017-18 onwards, is more than
prescribed limit (as per relevant notification), e-invoicing is mandatory.
What supplies are presently covered under e-invoice?
• Supplies to registered persons (B2B),
• Supplies to SEZs (with/without payment),
• Exports (with/without payment),
• Deemed Exports,
by notified class of taxpayers are currently covered under e-invoicing.
B2C (Business to Consumer) supplies can also be reported by notified persons?
No. Reporting B2C invoices by notified persons is not applicable/allowed currently. However, they will be brought under e-invoice in the next
phase.
Is e-invoicing applicable for NIL-rated or wholly-exempt supplies?
No. In those cases, a bill of supply is issued and not a tax invoice.
Whether the financial/commercial credit notes also need to be reported to IRP?
No, only the credit and debit notes issued under Section 34 of CGST/SGST Act have to be reported.
Whether e-invoicing is applicable for invoices between two different GSTINs under same PAN?
Yes. e-invoicing by notified persons is mandated for supply of goods or services or both to a registered person.
As per Section 25(4) of CGST/SGST Act, “A person who has obtained or is required to obtain more than one registration, whether in one State
or Union territory or more than one State or Union territory shall, in respect of each such registration, be treated as distinct persons for the
purposes of this Act.”
Do SEZ Developers need to issue e-invoices?
Yes, if they have the specified turnover and fulfilling other conditions of the notification.
In terms of Notification (Central Tax) 61/2020 dt. 30-7-2020, only SEZ Units are exempted from issuing e-invoices.
Are Free Trade & Warehousing Zones (FTWZ) exempt from e-invoicing?
Yes. As per Foreign Trade Policy, Free Trade & Warehousing Zones (FTWZ) are only a special category of Special Economic Zones, with a focus
on trading and warehousing.
Is e-invoicing applicable for supplies by notified persons to SEZs?
Yes, e-invoicing is applicable for supplies by notified persons to SEZs.
In terms of Notification (Central Tax) 61/2020 dt. 30-7-2020, only SEZ Units are exempt from issuing e-invoices.
• There is an SEZ unit and a regular DTA unit under same legal entity (i.e. having same PAN).
• The aggregate total turnover of the legal entity is more than Rs. 100 Crores (considering both the GSTINs). However, the turnover of
DTA unit is below Rs. 100 crores for FY 19-20.
• In this scenario, as SEZ unit is exempt from e-invoicing, whether e-invoicing will be applicable to DTA Unit?
Yes, because the aggregate turnover of the legal entity in this case is > Rs. 100 Crores. The eligibility is based on aggregate annual
turnover on the common PAN.
Is e-invoicing applicable to invoices issued by Input Service Distributor (ISD)? No
Whether e-invoicing is applicable for supplies involving Reverse Charge?
If the invoice issued by notified person is in respect of supplies made by him but attracting reverse charge under Section 9(3), e-invoicing is
applicable.
For example, a taxpayer (say, a Firm of Advocates having aggregate turnover in a FY is more than Rs. 100 Cr.) is supplying services to a
company (who will be discharging tax liability as recipient under RCM), such invoices have to be reported by the notified person to IRP.
On the other hand, where supplies are received by notified person from (i) an unregistered person (attracting reverse charge under Section
9(4)) or (ii) through import of services, e-invoicing doesn’t arise / not applicable.
How to know a particular supplier is supposed to issue e-invoice (i.e. invoice along with IRN/QR Code)?
On fulfilment of prescribed conditions, the obligation to issue e-invoice in terms of Rule 48(4) (i.e. reporting invoice details to IRP,
obtaining IRN and issuing invoice with QR Code) lies with concerned taxpayer.
However, as a facilitation measure, all the taxpayers who had crossed the prescribed turnover in a financial year from 2017-18 onwards
have been enabled to report invoices to IRP.
One can search the status of enablement of a GSTIN on e-invoice portal: https://einvoice1.gst.gov.in/ > Search > e-invoice status of
taxpayer
This listing of GSTINs is solely based on the turnover of GSTR-3B as reported to GST System. It may contain exempt entities or those
for whom e-invoicing is not applicable for some other reason. So, it may be noted that enablement status on e-invoice portal
doesn’t mean that the taxpayer is supposed to do e-invoicing. If e-invoicing is not applicable to a taxpayer, they need not be
concerned about the enablement status and may ignore it.
Further, the turnover slab of taxpayer can also be ascertained through “Search Taxpayer” / “Know Your Supplier” Sections on GST
portal also.
In case any registered person, is required to prepare invoice in terms of Rule 48(4) but not enabled on the portal, he/she may request
for enablement on portal: ‘Registration -> e-Invoice Enablement’.
In the current schema, there is no provision to report details of supplies not covered under GST, e.g. a hotel wants to give single invoice for a B2B supply where the supply includes food and beverages (leviable to GST) and Alcoholic beverages (outside GST).
For items outside GST levy, separate invoice may be given by such businesses.
In case of Credit Note and Debit Note, is there any validation w.r.t referred invoice number?
No linkage with invoice is built, in view of the amended provisions of GST.
Some HSNs which are otherwise valid are not accepted by e-invoice portal.
HSN directory is being aligned with GST System, so that it is updated and uniform on all systems, viz. Customs (ICES), GST System, e-way
bill system and e-invoice system.
Can I print an e-invoice?
• Yes. Once the IRP returns the signed JSON, your ERP/Accounting/Billing System it into PDF and printed, if required.
• Businesses who don’t have their own ERP/Accounting Software, will be downloading and using the free offline utility (‘bulk
generation tool’) to upload invoice data on e-invoice portal and obtain signed invoice (in JSON).
• In this scenario also, there is a facility on e-invoice portal to generate ‘human-readable’ PDF copy of invoice (for save/print/e-mail etc.).
Are there any penal provisions for not issuing invoice in accordance with GST Law/rules?
The penal provisions are provided in Section 122 of CGST/SGST Act read with CGST Rules.
If the above specified exempted taxable persons are having multiple business units, such multiple business units are also exempted from generation of E-
Invoices under GST Law,2017?
No, If the above specific exempted taxable persons are having multiple business units within the same GSTIN, we have to verify and ascertain the activities
of such multiple business units, which are not covered within the above mentioned exemptions.
Ex: If a Goods Transport Agency (GTA ) is having commercial Immovable property( Godown) and such services and his aggregate turnover exceeds more
than Rs.100 Crores , such person is not exempted for issuing E-Invoice. In my opinion, If the above specified person are having other business activities
along with the above mentioned exempted activates are not permitted to get exemptions from generating E-Invoices.
Can anyone generate E-Invoice through Common Portal of GSTN?
➢ No, Supplier only can generate E-Invoice. Others cannot generate E-Invoice like Recipient or Transporter through Common Portal of GSTN. In the case
of RCM also Supplier can generate E-Invoice but RCM tax liability under RCM discharged by Recipient only.
➢ Further, If the taxpayer is having aggregate turnover more than Rs.100 Cr, such taxpayer cannot issue E-Invoice to B2C supplies. If taxpayer can
generate E-Invoice continuously, the access of generation of E-Invoice system through Common portal will be blocked.
➢ Further , if the taxpayer issuing E-Invoice to supply of taxable and exempted supply of goods / or services under single invoice would be difficult, so, he
will be required to issue E-Invoice in respect of taxable supplies only. He cannot issue E-Invoice to exempted supply under the system of E-Invoice. He
can generate E-Invoice under his existing system/existing accounting system only
How to Validation of Invoice Reference Number (IRN) ?
➢ If the Invoice Reference Number is already generated on a particular type of document and document number of the supplier
for the financial year, then one more Invoice Reference Number (IRN) cannot be generated on the same combination.
➢ Maximum number of items in each invoice should not exceed more than 1000 line items and a minimum of 1(One) line item
should be available.
➢ If any taxpayer is required to report more than 1000 line items may contact NIC (National Informatics Center).
➢ Document number should not be starting with 0 , / and -.If so, then the request is rejected. In the case of Reverse Charge
transactions, The taxpayer can be set as “Y” in case of B2B invoices only and tax is being paid in a reverse manner as per rule. Even
in the case of RCM invoices (Reverse Charged Invoices) the supplier has to generate the Invoice Reference Number (IRN). So, in the
case of RCM invoices ,supplier can generate E-Invoices but Tax discharged on RCM Invoices by Recipient only.
➢ In case of any error invalidation, the error code and its details can be referred from https://einv-apisandbox.nic.in/api-error-
codes-list html.
Can a foreign service provider integrate with IRP
Yes, but only from within the shores of India
What is the definition of this and how can one become ASP?
ASPs are software service providers who route their GST traffic through GSPs. Any software provider of financial services in the indirecttax domain can push data to the GST system through GSPs.As far as IRP is concerned, access will be provided over the internet. No suchcategory of GSP/ASP will be created for access to IRP
Is the batch (bulk) submission of e-invoices to IRP allowed?
this will be enabled in API based mode.APIs will permit the upload of JSON payloads. The invoices shall be accepted one at a time,though you may push invoices sequentially. The system shall be designed so as to scale and respond to API requests so as to enable theacceptance of millions of invoices per day, to start with
What indicates for the supplier (and respectively) buyer that IRP has approved the e-invoice
The IRP will respond with a signed IRN to the seller. IRP will also return a QR code, with digital signatures of the IRP. The QR codecontent will be as published in the FAQs on our website (www.gstn.org/e-invoice)
Can a foreign service provider integrate with IRP
IRP will validate for GSTIN existence (of seller and buyer) and de-duplication of the invoice. If non-existent GSTIN and/or aduplicate invoice is found, the invoice will be returned with relevant error codes, without registering it
Can IRP reject the submitted invoice?Can IRP reject the submitted invoice?
. Is the supplier required to sign JSON before submitting it to the IRP?
It is optional.
N.N. 72/2019-CT Seeks to notify the class of registered person required to issue invoice having QR Code.
Registered Person Having turnover >500 Croresin any preceding F.Y from 2017-18 onwards
Issuing Invoice to Unregistered person
Unregistered Person
Invoice shall have Quick Response(QR)code.
Proviso
Provided that where such registered person makes a Dynamic Quick Response (QR) code available to the recipient through a digitaldisplay, such B2C invoice issued by such registered person containing cross-reference of the payment using a Dynamic Quick Response(QR) code, shall be deemed to be having Quick Response (QR) code.
N. N. 14/2020-CTThese provisions effectivefrom 01.10.2020 amended by71/2020 w.e.f 01-12.2020
Other than
Person covered under sub rule 2(Banking),3(GTA),4(Passenger Transport), 4A (Admission to
Exhibition, Films Muliplex) of Rule 54
N.N. 14/2020
N. N. 89/2020-CTNo penalty u/s 125 for the period 1st Dec,2020to 31st MArch,2021 if comply from 1st April
A QR code (abbreviated from Quick Response code) is a type of matrix barcode or
two-dimensional barcode
COMMON USES OF QR CODE
DEFINITION OF QR CODE
➢ QR code payment
➢ Displaying multimedia contents
➢ Mobile operating systems
➢ URLs
➢ Virtual stores
➢ Website login
➢ Restaurant ordering
➢ Joining a Wi-Fi network
➢ Funerary use
➢ TOTP use
➢ Video games
➢ Loyalty programs
➢ And many more……
IRP-generated QR Code on B2B & Export Invoices, Credit & Debit NotesVs.
Self-generated Dynamic QR Code on B2C invoices
BASIS IRP-generated QR Code Dynamic QR Code
Relation Related to Invoice Particulars Related to Digital Payments
Purpose To embed key particulars of reported invoiceand to verify whether an invoice has actuallybeen reported to IRP or not and whether digitalsignature is intact or tampered with.
To enable payment using UPI by a mobileapplication by scanning of this QR Code.
QR code to begenerated by whom
Generated by the IRP and returned against thee-invoice details reported to IRP.
Supplier himself either on the Point of Sale(PoS) machine or the Invoice issued.
Type of transactioncovered
B2B and Export supplies B2C supplies
GST Notification No. 68/2019- Central Tax Dated 13-12-2019,13/2020- Central Tax Dated 21st March,2020 &61/2020 Dated 30-07-2020
14/2020- Central Tax dated 21st March,2020
IRP-generated QR Code on B2B & Export Invoices, Credit & Debit Notes
As per Rule 48(4) of CGST Rules (inserted vide Notification No. 68/2019 – Central Tax Dated 13-12-2019 and
read with other notifications), notified registered persons, in case of B2B & Export supplies, have to prepare
invoice by uploading specified particulars in FORM GST INV-01 on Invoice Registration Portal (IRP) and upon
obtaining Invoice Reference Number (IRN). The Portal will also return a QR Code which contains key
particulars of the invoice including IRN.
While the 64-character IRN need not be printed on the invoice, the QR code generated by IRP shall be
printed on the invoice issued to the buyer.
(It was also clarified that printing of QR code on separate paper is not allowed. While the printed QR code shall
be clear enough to be readable by a QR Code reader, the size and its placing on invoice is upto the preference
of the businesses.)
Self-generated Dynamic QR Code on B2C invoices
There is a separate Notification No. 14/2020-Central Tax dated 21st March, 2020 which mandates entities with
aggregate turnover > Rs. 500 crores in a FY to include QR code on their B2C invoices. It was also specified
that a Dynamic Quick Response (QR) code made available to buyer through digital display (with payment
cross-reference) shall be deemed to be having QR code. In this case, the QR Code is generated by supplier
himself.
Purpose of Dynamic QR code
The main purpose of the introduction of dynamic QR code in
the GST system is to enable payment using any UPI.
The buyer can scan the dynamic QR code and make
payment from mobile wallet directly. Today, many shops
have static QR code at the payment counter which is
scanned by the buyer but the buyer has to enter the
amount to be paid to the shop (in the mobile payment App).
The dynamic QR code, on the other hand, will have the
payment details and thus ‘scan and pay’ in one go will be
possible.
HOW TO GENERATE DYNAMIC QR CODE
Through GSP’s appointed by GSTN providing solutions and APIs enabling taxpayers with GST compliances by
generating the same either by integrating an API or by developing code on clients’s existing PoS machine
or mobile app/website i.e., used for generating B2C invoices. Once a dynamic QR code is generated
customers can instantly pay by scanning the same using UPI-based payment apps.
DATA EMBEDDED IN DYNAMIC QR CODE
1.Merchant’s UPI Id.
2.Merchant’s Name.
3.Merchant Code, if any.
4.Merchant ID, If any.
5.Reference number that may consist of an order number,
subscription number, Bill number, booking number, etc.
6.Short Description.
7.Invoice Value.
8.Minimum Amount Payable
BY:CA AANCHAL ROHIT KAPOORM. No. 9988692699, 9888069269
E-mail :[email protected]
Disclaimer The views expressed are solely of the author and the content of this document is solely for information purpose and not to be construed as a professional advice. In cases where the reader has any legal issues, he/she must in all cases seek independent legal advice.
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