E-invoicing system for e-Commerce Operators

Posted on by CMA Bhogavalli Mallikarjuna Gupta

The e-invoicing system is also available for the E-Commerce Operators (ECO) to
report the invoices to the Invoice Registration portal, generated by them on behalf
of the suppliers. The e-invoicing system identifies the e-Commerce operators based
on the taxpayer type in the GST registration details. The taxpayer having the type
as ‘TCS’ will be enabled for reporting invoices on the e-invoicing system as eCommerce Operator.
However, it is important to note that E-commerce transactions can be reported by
the E-commerce operators with “EcmGstin” attribute as their GSTINs. This means
to say, that apart from specifying the Seller GSTIN in the payload, it is mandatory
to specify the e-Commerce operator GSTIN in the “EcmGstin” attribute of the
schema by e-Commerce Operator when he logs in using his user credentials.

  1. e-Invoice APIs available for e-Commerce Operators
    • Generate IRN (for self or on behalf of suppliers)
    • Cancel IRN (applicable to only for those IRNs, generated by e-Commerce
    operator)
    • Generate E-Waybill
    • Cancel E-waybill (applicable to only for those IRNs generated by e-Commerce
    operator)
    • Get IRN (applicable to only for those IRNs, generated by e-Commerce operator)

  1. Scope of Access to IRNs generated by e-Commerce operator and Supplier
  1. Process for integrating on the Sandbox system
    The following procedure has to be followed by the e-Commerce operators to
    integrate their ERP systems to the sandbox system of IRP.
    • The Registration module in the sandbox system has an option ‘E-Commerce
    Operator’
    • The e-Commerce Operator may select this option and enter the GSTIN of type ‘TCS’
    and get registered in the sandbox portal, by authenticating with OTP sent to the
    GSTIN registered mobile.
    • API credentials such as Client-Id, Client-Secret, User-name and Password may be
    generated.
    • On logging into the sandbox tool, there is no need to add the GSTINs.
    • The payload to generate the IRN may be prepared and tested in the sandbox tool.
    • As already mentioned, the payload shall contain the Seller GSTIN, Buyer GSTIN and
    also the e-Commerce GSTIN along-with other details.
    • All other validations and schema and procedure mentioned in the sandbox portal
    may be followed.
    • While using the ‘Cancel IRN’,’ Generate EWB by IRN’, Cancel EWB’, ‘Get IRN’, send
    the ‘Supplier GSTIN’ in addition to other parameters
  1. Process for integrating on the Production system
    The following procedure may be followed by the e-Commerce operators to
    integrate their ERP systems to the production system of IRP.
    • The TCS registered taxpayer will need to do login registration in the Invoice
    registration portal (https://einvoice1.gst.gov.in). If already registered, the
    taxpayer can login to the Invoice registration portal.
    • Select the API registration.
    • Submit the application for whitelisting the IPs along with summary test report. Up
    to 4 Indian Static IPs are allowed.
    • On submission of the application, the network team will scrutinize and whitelist
    the IPs.
    • API credentials such as Client-Id, Client-Secret, User-name and Password may be
    generated.
    • Create the username and password for the other PAN related GSTINs by selecting
    the above GSTIN.
    • Use above credentials, the payload to generate the IRN, may be prepared and IRN
    may be generated.
    • As already mentioned, the payload will contain the Seller GSTIN, Buyer GSTIN and
    also the e-Commerce GSTIN along with other details

Changes in the e-invoice Validations Architecture

Posted on by CMA Bhogavalli Mallikarjuna Gupta

e-invoicing is implemented in India from 1st Oct 2020 for taxpayers having turnover above ₹ 500 crores and now the threshold has been reduced to ₹ 50 crores from 1st April 2021. The pace at which the Indian businesses have adopted is remarkable and all the credits to NIC for putting in place robust infrastructure which as ensured seamless experience to the taxpayers without any major glitches. The e-invoicing system is also undergoing constant changes from time to time based on the dynamic requirements of the taxpayers and their feedback. Some of the changes are announced and architectural changes have been made and they are

a) The existing Authentication API ver 1.03 is replaced with ver 1.04 from 10th April 2021

b) Two new attributes have been added to the response JSON for “Get GSTIN Details” & “Sync GSTIN Details” and the newly added attributes are

i) Date of Registration

ii) Date of De-registration

c) IRNs cannot be generated if the Supplier or Recipient GSTINs are in “Suspended”, “Provisional” or “Inactive” or “Cancelled” status. This validation will ensure that IRNs are not generated for such recipients and will minimize the taxpayers exposure to that extent.

d) If the Registration status of the Supplier or Recipient is in “Cancelled” status, the document date should be between the Date of Registration and Date of De-registration. This validation will ensure that business is not impacted and the supplier will know the status of the recipient at the time of issue of invoice only and enable him to take commercial decisions accordingly.

e) If the recipient is an SEZ Unit or SEZ developer, supply types “SEZWP” or SEZWOP” are only enabled and rest of the supply types are disabled to provide better user experience with proper and meaningful validations.

f) The validation for the number of digits for the HSN code is also enhanced to meet the latest regulatory changes. The minimum number of HSN codes has been increased to 6 digits for taxpayers above ₹ 5 crores.

g) While generating E Way Bill, Vehicle Type (‘VehType’) can be set to ‘O’ (Over Dimension Vehicle) if the Transportation mode (‘TransMode’) is set as ‘4’ (Ship).

Even though the above validations are few but they are really taxpayer friendly by way of providing better user experience and also minimizing the exposure towards the errant taxpayers thereby safeguarding the genuine taxpayers. The increase in validation for HSN codes for taxpayers having turnover above ₹ 5 crores to 6 digits means that e-invoicing sooner or later will be applicable to taxpayers who are having turnover above ₹ 5 crores.

Important changes applicable from 1st of April 2021 in GST

Posted on by CMA Bhogavalli Mallikarjuna Gupta

From 1st April 2021, some changes are being made in Goods and Service Tax which taxpayers have to follow and implement the same.

e-invoice

e-invoice is required to be issued by all registered taxpayers having turnover above rupees fifty crores for all B2B transactions.

  • Display of HSN codes on Tax Invoice

Taxpayers having turnover above rupees five crores are required to show six HSN code digits on all tax invoices.

Taxpayers who are having turnover below rupees five crores are required to show four digits of the HSN code in case of B2B (Business to Business) and B2C (Business to Customers) optional to show HSN codes.

  • Changes in HSN Summary while filing GSTR – 1

While filing GSTR – 1 on a monthly or quarterly basis, the taxpayers have to report the HSN codes as discussed in Point Number 2 in the HSN Summary that is in Table 12 of GSTR – 1.

Cost of Non-Compliance

The cost of non-compliance is always higher than than the cost of compliance. In case if the taxpayers are not adhering to the above changes, then the department can levy a penalty under Section 125 of CGST Act 2017, residuary penal provision of rupees twenty-five thousand for Central Goods and Service Tax and another twenty-five thousand rupees for the State Goods and Service Tax thereby making the penalty amount to rupees fifty thousand.

Taxpayers are requested to make necessary changes in their business process and accounting or billing software or return filing solutions accordingly else the penalties will be levied.

e-invoice threshold changes from 1st April 2021

Posted on by CMA Bhogavalli Mallikarjuna Gupta

e-invoice is being implemented in India very aggressively compared to other nations across the globe. Within a span of 6 months we could see the changes in the threshold and also the number of e-invoices issued. It all started from 1st Oct 2020 for taxpayers having turnover above Rs 500 Crores. The same has been decreased to Rs 100 Crores from 1st Jan 2021 and now it is further reduced to Rs 50 Crores from 1st April 2021.

The number of e-invoices issued has already crossed 25 crores on 3rd Feb 2021 and the count is increasing.

As per Notification no 5-Central dated 8th March 2021, e-invoice is applicable for taxpayers having turnover above Rs 50 crores. This is a good news compared to the initial talks of Rs 5 crores from 1st April 2021.

Frequently Asked Question on e-invoicing

Posted on by CMA Bhogavalli Mallikarjuna Gupta

Q: Purpose of the API

Ans: To get invoices uploaded in IRP and their status of auto population in GSTTR1. Even if you change any value in GSTR1 for auto populated invoice, this API will always return data uploaded in IRP.

Q: If GET E Invoice API is used to pull the data from e Invoice (IRP portal) whether it will auto populated into GSTR 1 or ASP should get the data into system and do another action with Save GSTR 1

Ans: GST System is fetching this data and also auto populating it in GSTR1. This API is returning data fetched by GST System from IRP. So all auto populated invoices will be also available in getB2B/getCDN… APIs of GSTR1.

Q: If the data is auto populated from IRP via push then we don’t see any data auto populated in GSTR 1 till now?

Ans: It has not yet gone to production yet.

Q: If the data is auto populated from IRP did user required to push again the same data via save GSTR 1?

Ans: Not required.

Q: Please confirm that IRN generated date will be the KEY for Return period determination.

Ans: No return period will be determined from invoice date as per current design.

Q: What is the purpose of those new field Auto Draft status, Auto Drafted Date, Error Code and Error Message in get Einvoice API. Can you throw some light on what these fields are?

Ans: It is for, whether Invoice got auto drafted in GSTR1 or not, date of auto drafting, if there is any error in auto drafting then error code and message.

Q: What will be the filing flow of GSTR-1 after implementation of this new API?

Ans: GSTR-1 flow is to be same as present.

Q: Is it always necessary to fetch E-invoice data before filing or can we upload imported data?

Ans: No it is not necessary but it is a good practice to do reconciliation, so that over writing of auto populated data can be avoided. Also successfully auto populated data will be available through getB2B/getCDN ….APIs of GSTR1 also.

Q: What will be the change in SAVE API? IS there any increase in save Parameters like- IRN no. and/or IRN date etc?

Ans: There will be no new addition.

Q: It is mentioned in Excel attribute that ctin wise data can also be fetched however the same parameter is not available in request URL

Ans: for getEinvoice api it is not available for attribute sheet or url

Q: In b2b section, Invoice type-CWB (Custom Bonded Warehouse) is also available, how we are deriving this parameter because no such information is going in IRN generation?

Ans: It will not come from IRP. As save and get APIs are for GSTR1 and in GSTR1 this field exist, so it will remain in APIs but will not be available in data auto populated through IRP data.

Q: In request payload for get Einvoice API, there is afrom_date field, which date will be considered for this from_time. E.g. an invoice for which IRN is generated has following dates Document date is 10/10/2020, IRN generation date is 12/10/2020 and Auto Populate date is 13/10/2020. What from_time we need to send in request payload in order to get this invoice?

Ans: It can be used to get data after a particular date-time. It will be based on auto population date (GST System receipt date)

Eg: consider that Document date is 15-10-2020 and it is added into GST system on 19-10-2020. If from_time is specified as 16-10-2020, as it was inserted on 19-10-2020 that document will be part of response.

Q: The field Ack no., Ack. date, signed QR are not added in any of the APIs. (Even not in GET Einvoices API) Will these be included at a later stage?

Ans: There is no plan to include it. IRN will be the key for all auto populated data.

Q: If IRN auto populated data is edited then will that flag also be available in Get B2B/CDN/EXP/CDNUR?

Ans: Source, IRN no and date  will be removed once auto populated data will be edited through GSTR1 Online/Offline/API save.

Q: If we send any delete request from API for an invoice which is already auto populated in these sections, then will it be deleted from this section or retained with a flag marked as Deleted?

Ans: Record will be deleted from only GSTR1. It will be available in get einvoice API.

Q: If someone deletes the full auto populated data from these sections and then save all invoices again (all data may be same or edited in some invoices and not edited in some) through API or added from UI or offline tool, then will it be compared with the “Get Einvoice” data and will the IRN nos and date be brought back to this collection for respective invoices? 

Ans: Data coming from E-invoice (IRP) will be kept separate and it will not change. User can edit anything in GSTR1 and GSTR1 will reflect changed data. This change will be tracked for analysis purpose.

Q: If there are some invoices in “Get Einvoice (New API)” and the status of IRN is Cancelled then these will not be auto populated in “Get B2B/EXP/CDNUR/CDNURA” collections. Let us know if our understanding is correct.

Ans: There are many scenarios around it:

  • If cancelation happen on the same day. Data will be available in getEinvoice API but not be auto populated in GSTR1.
  • If cancelation happens next day than it will be first auto populated in GSTR1 and on cancelation it will be deleted from GSTR1 if user has not edited that invoice,
  • If user has edited GSTR1 data then nothing will change in GSTR1.

Q: Earlier we had asked this question but at that time it was still under discussion, is it now decided? Which date will be considered for auto population: Document Date or IRN generation date? Let us know if our understanding below is correct in the example: 

If Document date is 28.10.2020 but IRN is generated on 05.12.2020 

(a) if Oct 2020 return is not yet filed, then this document will be populated in Oct 2020 month

(b) If Oct 2020 return is already filed then this document will be populated in Nov 2020 month

(c) If Nov 2020 return is also already filed then this document will be populated in Dec 2020 month (i.e. open month)

Ans: As per current implementation if return is filed than records coming for that period in future will only available in getEinvoice API of October month only. It will not be auto populated in any other period.

Q: While saving invoice data through APIs, if we are sending all invoices that are already auto populated by GSTN, again for save, without changing any data, then will it also be flagged that it is edited? Additionally, in such cases or any cases where any edit is done through API, the fields like IRN, source type and IRN generation date will still be retained or removed? 

Ans: Please refer ansers above

Q: When are the APIs expected to be released to us on sandbox for testing? 

Ans: It will be by mid of next week. Provide time. I think we are only releasing getEinvoice API. Not autopopualtion to GSPs.

Q: Currently there are no common GSTINs on sandbox for einvocing and GSTN. So how will we do the testing for the same? Will we be allowed to add GSTN sandbox GSTINs on einvocing portal? or will the einvocing/NIC test GSTINs will be automatically added in GSTN portal?

Ans: We will provide you some GSTIN for testing.

Advisory on challenges in Auto Populated of GSTR – 1 for e-invoices

Posted on by CMA Bhogavalli Mallikarjuna Gupta

Taxpayers having turnover above Rs 500 crores are required to issues e-invoices from 1st Oct 2020.

As part of Digitization, e-invoices issued by the taxpayers will be auto-populated to GSTR – 1. This was supposed to happen from 13th Nov 2020. Due to some unforeseen technical issues, the same is not happening as planned.

Taxpayers who are waiting for the auto-population are advised to file the returns for the month of November 2020 and not to wait for the same.

e-invoice data will be auto-populated into GSTR – 1 from the tax periods October and November will start from 13th December 2020 and it is expected to take couple of weeks.

e-invoice data for the month of December is expected to be auto-populated from the first week of December in T+2 days.

Source – https://www.gst.gov.in/newsandupdates/read/421