Changes in
E-invoicing,
Debit notes and
Credit notes
2 days GST refresher course
22nd January 2023
STAR
CA. Deepak Bhholusaria
This presentation is only for knowledge sharing
Disclaimer
This presentation has been prepared for
academic use only for sharing knowledge
on the subject. Though every effort has
been made to avoid errors or omissions
in this presentation yet any error or
omission may creep in.
It is suggested that to avoid any doubt
the user should cross check the
correctness of text, contents and the law
with the original documents and to dispel
confusion should seek professional
help/opinion.
About presenter
• Mr. Deepak Bhholusaria is a
commerce graduate and fellow
member of the Institute of Chartered
Accountants of India.
• He has also completed various
certificate courses of ICAI on Indirect
taxes, Blockchain, Information
Systems Audit and Valuation.
• A seasoned professional, author,
speaker, public figure and YouTuber
with 24 years of experience.
3
Period covered
st
1
January 1st 2022
to
st
31 December 2022
Changes related
to Debit and
credit notes
STAR
दक्षम:
Section 34(2)
Time limit to issue credit notes
Pre amended till 30/09/22
Post amendment w.e.f. 01/10/2022
(2) Any registered person who issues a
credit note in relation to a supply of
goods or services or both shall declare
the details of such credit note
(2) Any registered person who issues a
credit note in relation to a supply of
goods or services or both shall declare
the details of such credit note
in the return for the month during
which such credit note has been
issued but not later than
in the return for the month during
which such credit note has been
issued but not later than
September
the thirtieth day of November
following the end of the financial year
in which such supply was made, or
the date of furnishing of the relevant
annual return, whichever is earlier,
following the end of the financial year
in which such supply was made, or
the date of furnishing of the relevant
annual return, whichever is earlier,
and the tax liability shall be adjusted in
such manner as may be prescribed
and the tax liability shall be adjusted in
such manner as may be prescribed
Credit note – Impact
Pre amended till 30/09/22
Post amendment w.e.f. 01/10/2022
• Credit note for a financial year
could be declared in GSTR-1 till the
month of September of next FY.
• Credit note for a financial year
could be declared in GSTR-1 only till
30th November 2022.
• Date of filing of such GSTR-1 was
irrelevant
• Effectively such CN can now be
declared in next year’s GSTR-1 of
October, but with a condition that
such GSTR-1 is filed latest by 30th
November.
• E.g., A credit note issued on
31/03/2022 could be declared in
September 2022 GSTR-1.
•
•
• E.g., A credit note issued on
31/03/2022 could be declared in
October 2022 provided GSTR-1 is
filed by 30th November 2022
Can I issue credit note for supplies effected in FY 2021-22, on 1st February
2023?
Can common portal recognise that such CN dt. 01/02/2023 is in relation to
supply of FY 2021-22?
QRMP?
• What if registered tax payer is following
QRMP scheme?
• Due date for GSTR-1 of Q3 (Oct~Dec) in such
case is 13th January 2023.
Solution:
➢Such tax payer could opt for Monthly GSTR-1
for Q3 by 31st October 2022 and then for Q4
could revert back to QRMP.
➢This move was also necessitated to avail ITC
within new due date u/s 16(4)
Changes related
to E-Invoicing
law
STAR
दक्षम:
What is E-invoice?
STAR
10
Concepts of E-invoice
Rule 48(4) of CGST Rules –
•
•
•
•
•
•
Notified class of RP (500cr  100cr  50cr  20cr  10cr )
have to prepare invoice
by uploading
Specified particulars of invoice (see INV-01)
on Invoice Registration Portal (IRP) and
obtain an Invoice Reference Number (IRN).
This is 1st step
 No change per se in Rule 48(4) except changes in AATO limits!
11
Concepts of E-invoice
Rule 46(r) of CGST Rules –
Subject to rule 54, a tax invoice referred to in
section 31 shall be issued by the registered person
containing the following particulars, namely,-
(r) Quick Response code, having embedded Invoice
Reference Number (IRN) in it, in case invoice has
been issued in the manner prescribed under subrule (4) of rule 48.
This is 2nd step
12
How is ‘e-invoicing’ different
from present system?
• Registered persons 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 returns the e-invoice with a
unique ‘Invoice Reference Number (IRN)’
after digitally signing the e-invoice and
adding a QR Code.
• Then, the invoice can be issued to the receiver
(along with QR Code).
Process of E-invoice
Prepare
Regular
Invoice
Obtain IRN,
QR code and
signed JSON
from IRP
Convert
to JSON
Upload
JSON to
IRP
Issue invoice
with IRN &
QR Code to
recipient
STAR
Concepts of E-invoice
Invoice
IRN
from
IRP
QR
Code on
Invoice
E-invoice
15
How does QR code and IRN looks
like?
940265ef080519e005
09ece80b8976947ce2
8a9b2f2d2461a15cc2
d3fde57156
Please note!
Please note that
‘e-invoice’
in
‘e-invoicing’
doesn’t mean
generation of invoice
by a Government
portal
Legal Framework
E-invoice
Rules
46(r)
QR code on
Invoice
46(s)
Declaration
on Invoice
48(4)
Manner of
E-invoice
Notifications
48(5)
138A (2)
Non
Treatment
of Invoice
QR Code
Instead of
Invoice
13/2020
Category
of RPs
 Not. 13/2020 is further amended by 61/2020, 70/2020, 88/2020, 5/2021, 01/2022 & 17/2022
60/2020
GST INV-I
Process Flow
Is 5Cr limit notified?
Who is in?
Sl#
Class of registered
persons having
aggregate turnover
exceeding
Applicability
date
1.
500 cr*
1st October 2021
2.
100 cr
1st January 2021
3.
50 cr
1st April 2021
4.
20 cr
1st April 2022
5.
10 cr
1St October
2022
* As a one time exception, RPs (> 500 cr) were allowed to generate IRN for Oct
2020, within 30 days from the date of invoice (Not. No. 73/2020)
Who is out?
SEZ Unit
(not developer)
Insurer
Banking Company
Financial
Institution
NBFC
GTA
Passenger
Transport
Multiplexes
ISD Invoices
A Govt
Department
Local Authority
 There is no change in this exemption list during 2022
How do you know if supplier is
exempt from e-invoice?
• Rule 46(s) inserted from 5th July 2022 vide
not. No. 14/2022
• Such exempted entities (if otherwise
covered by e-invoice) to declare in invoice –
“I/We hereby declare that though our aggregate
turnover in any preceding financial year from
2017-18 onwards is more than the aggregate
turnover notified under sub-rule (4) of rule 48,
we are not required to prepare an invoice in
terms of the provisions of the said sub-rule.”
Section 2(6) : Aggregate Turnover
Exempt
Supplies
Export
supplies
All Taxable
supplies
Except Inward
Supplies on which
tax has been paid
under reverse
charge
Aggregate
Turnover
Inter
state
supplies
excludes: All kinds of taxes under GST
To be computed on all India basis for person(s) having same PAN
Period to check
31/03/2022
31/03/2021
01/04/2020
01/04/2019
01/04/2018
01/07/2017
If any RP cross threshold in any FY out of these 5, provisions of E-invoice shall
be applicable for life time. This is to rest applicability of e-invoice in FY 2022-23
Slide No. 25
What kind of supplies/docs are
covered?
• B2B – Tax Invoice, Debit Note, Credit
Notes
• Export / Zero Rated – With or without tax
(including related Debit and credit notes)
• Deemed Export
• Supply to Distinct Person (Deemed Supply)
What about High sea sales and bonded warehouse sales?
What about imports?
What kind of supplies/docs are
NOT covered
• B2C
• Bill of Supplies / Exempt Supplies
• Delivery Challans / Job Work Challan
• Import
• ISD
What about financial credit notes, in relation
to B2B supplies?
What about self generated RCM Tax Invoices?
Implications on credit
Section 16 Eligibility and conditions for taking input tax
credit.
…
(2) Notwithstanding anything contained in this section, no registered
person shall be entitled to the credit of any input tax in respect of any
supply of goods or services or both to him unless,–
(a) he is in possession of a tax invoice or debit note issued by a
supplier registered under this Act, or such other tax paying
documents as may be prescribed;
Rule 48(5)
…
(5) Every invoice issued by a person to whom sub-rule (4) applies in
any manner other than the manner specified in the said sub-rule shall
not be treated as an invoice.
 Legality of rule 48(5) in the opinion of presenter seems to be ultra vires section 31
Time limit to issue e-invoice
•No time per se notified
•Time limit to decide as
per section 31
STAR
e-invoicing &
tech related
changes
STAR
दक्षम:
Auto population in GSTR-1
• E-Invoices, e-debit notes & e-credit notes
after generation on the IRP are then
transmitted electronically to the GST system
within 2 days
• These are auto-populated in the respective
tables of GSTR-1, in the month for which docs
were generated.
• Auto populated docs appear as “Saved”
records with source mentioned as “E-invoice”
Auto population in GSTR-1
• The auto populated records can be manually
edited but “source” will change.
• Records can be manually added to GSTR-1
prior to generation of e-invoice. In such case
e-invoice data will not overwrite data already
present in GSTR-1
• E-invoice can be generated even after filing of
GSTR-1 but then it will not auto populate to
any month. Not even in subsequent month.
•.
E-invoice data in Excel format
• An additional facility of consolidated
download of all documents auto-populated
from IRP is made available in GSTR-1
dashboard.
• This Excel file is available on the GSTR-1
dashboard for the tax-period to which the
document (invoice, debit note, credit note)
pertains to.
STAR
E-invoice data in Excel format
The Excel file contains document-wise details (invoice, debit note,
credit note) reported on the IRP and the following details for all
documents :
1. Invoice Reference Number (IRN) – 64 string hash
2. Date of Invoice Reference Number (IRN date)
3. e-invoice Status – Valid / Cancelled
4. Date of auto-population/deletion upon cancellation – Date of
auto-population into GSTR-1 in case of valid IRN, or, the Date
of deletion in case of cancelled IRN, as the case may be
5. GSTR-1 auto-population / deletion status (either of the
following) :
6.
•
•
•
•
Auto-populated,
Deleted,
Auto-population failed,
Deletion failed
Error in auto-population/ deletion – Error description, if any
E-Invoice verification Mobile App
STAR
New GePP-on
portal
GST e-invoice Preparing and Printing
दक्षम:
Home Screen
Create Invoice Screen
Create Invoice Screen
Create Invoice Screen
Create EWB along with invoice
Save or generate
Various cancel IRN options
STAR
STAR
Open House
दक्षम:
Slide No. 44
Thanks for your
time!
STAR
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