Frequently Asked Question on e-invoicing

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 auto-population of e-invoice details into GSTR-1

  1. Certain notified taxpayers have to prepare and issue their invoices by obtaining Invoice Reference Number (IRN) from Invoice Registration Portal (IRP) (commonly referred as ‘e-invoices’).
  2. Upon successful generation of IRN, details of such e-invoices will be auto-populated in respective tables of GSTR-1. The same can be downloaded as excel file as well.
  3. In case the GSTR-1 for corresponding period was already filed by the taxpayer, then, the details from einvoices can be downloaded as excel file only.
  4. The details would be auto-populated based on document date.
  5. Auto-population into GSTR-1 is as follows:
Sr.NoSupply TypeColumns of GSTR – 1 Auto-populated
1Outward Supplies to Registered Person, other than Reverse ChargeB2B – 4A transactions expect for the following transactions i)Supplies attracting reverse charge ii)Supplies made through e-commerce operations
2Outward Supplies to Registered persons attracting reverse chargeTable 4B
3Export SuppliesTable 6A – Exports
4Credit/Debit Notes Issued to Registered personsTable 9B – CDNR
5Credit/Debit Notes issued for exports (unregistered persons)Table 9B – CDNUR

6. The item-level details in the document will be aggregated at rate-level for the purpose of auto-population
into GSTR-1. For the auto-populated invoices, below additional details will also be displayed.
a. Source (e-invoice)
b. Invoice Reference Number (IRN)
c. Invoice Reference Number Date (IRN Date)

7. After auto-population of details from e-invoices, in case of cancellation of IRN, such documents will be
deleted in the respective table.

8. Details of e-invoices auto-populated in GSTR-1 can be edited/deleted by the taxpayer. However, in such cases, the ‘Source’, ‘IRN’ and ‘IRN date’ fields will be reset to blank in respective tables of GSTR-1. Such edited documents will be treated as if they were not auto-populated but uploaded separately by taxpayer.

9. Before filing GSTR-1, taxpayers are advised to review the details of e-invoices auto-populated in specified tables:

a. By viewing them online on GST Portal, or
b. By downloading the JSON from GST Portal, or
c. By using APIs via GSP

  1. Taxpayers are advised to modify/update only those documents where the details auto-populated from einvoices are not as per the actual invoice issued.
  2. Taxpayers are required to add details of supplies made in respective tables of GSTR-1, other than those
    auto-populated from e-invoices.
  3. An additional facility of consolidated download of all documents auto-populated from e-invoices is
    available in GSTR-1 dashboard. For this, you can use ‘Download details from e-invoice (Excel)’ button
    on GSTR-1 dashboard.
    It may to be noted that the auto-populated details in this excel file are as reported on e-invoice portal
    Invoice Registration Portal (IRP). So, any subsequent modifications made to the auto-populated
    documents (in GSTR-1 tables) would not be reflected in this excel file.
  4. Taxpayer can use the link ‘e-invoice download history’ to view the list of last five downloaded files. On
    click of the link, you can download the file.
  5. The excel file downloaded from GSTR-1 dashboard page will have details of all the e-invoices received
    from Invoice Registration Portal (IRP) including cancelled invoices.
    Following additional information relating to such e-invoices will also be available:
    a. Invoice Reference Number (IRN) – 64 string hash
    b. Date of Invoice Reference Number (IRN date)
    c. e-invoice Status – Valid/ Cancelled
    d. Date of auto-population/ deletion (in case of canceled IRN) will be the date when the e-invoice
    details are auto-populated in GSTR-1 or when the IRN was cancelled. Any subsequent
    modifications made to the auto-populated documents (in GSTR-1 tables) would not be
    reflected in this excel file.
    e. GSTR-1 auto-population / deletion status (either of the following):
    • Auto-populated,
    • Deleted,
    • Auto-population failed,
    • Deletion failed
    f. Error in auto-population/ deletion – Error description, if any

Role of Technology in GST 2.0

Goods and Service Tax has been rolled out in India from 1st July 2017, and now it is about 28 months, and during this period, we have seen a lot of changes being announced by the Government. The roll out of GST is dubbed to be the largest reform after Independence, but in reality, it is a business process reform as the trade and industry have to change their business process, and also, the Department has adopted technology and started doing data analytics to find out the errant taxpayers. All these are the things of the past,  there are a lot of changes being announced, and for that, the trade and industry have adopted to them else they will receive the same as a shocker like the roll out of GST or matching of invoices for availing the input tax credit.

As we are in the era of digitization from banking to day to day payments, if we do not embrace technology, we will be missing the bus, and it will impact the top line and bottom line of our business. In GST, very important changes are announced, and some of them are already effective some or going to be rolled out in 2020. The areas in which technology can help us to run our business smoothly and without

Matching for availing input tax credit

One of the major changes seen in GST is in the Return filing process. In the erstwhile tax regimes, the filing of returns was done manually or in some cases, filed electronically. There was no validation between the suppliers’ returns and the buyers’ returns, but in GST, it is implemented as the Government was to weed out the black sheep from the system. Matching was part of the GST law and the return formats, but it has to be deferred as small taxpayers were not used to it and did not have the know-how of doing the same. Now the same has been made effective from 9th Oct 2019 through Notification No 49 – Central Tax. The taxpayer is eligible to take input tax credit only based on the supplies filing of GST Returns. Invoices uploaded by the supplier has to be matched with the buyers purchase register, this can be done manually if the number of transactions is less as in case of small traders but in case of medium to large organizations where there are thousands of purchase invoices and multiple GST Registration Numbers, matching manually is a challenge, technology can adopt us the do this job seamlessly. There are various solutions available in the market where the GSTR – 2A data can be imported using the API’s and then uploading the purchase register with the relevant data, matching will be done seamlessly and accurately.

Adoption of technology for this activity not only saves time but also safeguards the organizations from paying interest and penalty on account of availing input tax credit wrongly due to human errors.

e-invoice

Tax evasion is one of the biggest challenges which the Governments face across the globe, and as part of it, many of them have adopted/implemented e-invoicing. If technology is adopted, e-invoicing is very simple. The suppliers will generate the tax invoice in his system and send the data through APIs (without human intervention) to the Invoice Registration Portal (IRP), and once the IRP validates the data, a unique number is generated and sent back. The same is imported, and the tax invoice can be printed. All these activities take place with the help of technology and happen in a matter of a few seconds. It will ensure that there are no disruptions in the business process; alternatively the taxpayers can upload the data manually on the IRP, but there will be room for data entry and human errors; this will lead to another set of compliance issues.

IRP not only generates the IRN but also shares the data with the supplier and updates in Anx -2, updates the Anx- 1 of the supplier, and also generates the Part – A of the e-waybill. In a nutshell, the adoption of technology for one activity has resulted in the accomplishment of three different tasks.

e-invoice is being rolled out from 1st Jan 2020 voluntarily and for B2B transactions, with matching in place for availing input tax credit, this makes the life of taxpayers very easy if the technology is adopted and taxpayers start issuing e-invoices.

New Returns

As a part of the simplification of the GSTR Return filing process, the Government has consolidated multiple returns into a single return with annexures. This is a welcome move, but again, this requires some changes in the business process and the way transactions are recorded.

The major shift we have seen in GST is filing of returns electronically and reporting of transaction data, but with the new format for GST returns, the Government is going one step ahead and is asking the taxpayers to report the same at the HSN level. It means that the taxpayers have to start filing the returns at the invoice line level or group at the HSN level if there are multiple lines on the invoice with the same HSN. This activity cannot be done manually, and for this, digitalization is required, and there are no exceptions for filing. The only exception is for the periodicity of return filling but not for the data. To make the life of MSME’s simple and easier before the rollout GST, the Government has shortlisted and validated free accounting software for MSME to adopt them.

Entering the data manually will only complicate the process and gives room for human and data entry errors. As the new returns are applicable from 1st April 2020, the taxpayers should have a plan for the adoption of digital ways for the issue of tax invoices so that the return filing is accurate and duplication of work is avoided.

GST Audit / Annual Returns

Every taxpayer who has to file the GST Annual Return GST Audit, the data to be uploaded in the returns are at a micro-level. Being the initial years of rollout of GST, many of the taxpayers are not having the data required for filing of the GST Annual Return. To give legroom for the taxpayers, the Government has relaxed the requirements for the first two years, but going forward, the micro-level data has to be uploaded.

The data has to be captured at the transaction creation time only, and it cannot be done as a post-mortem activity. For the data to be in place, again, digitalization is the only solution. This will help in the maintenance of the books of accounts easily and being GST compliant. For this, the taxpayers have to revisit their ledgers/chart of accounts and create new once wherever necessary, so that the transactional data is updated accordingly.

Apart from the ledgers, the HSN summary and tax rate wise data also have to be uploaded; this is possible only if the taxpayers have a proper accounting system in place. For small taxpayers, it may not be a challenge, but for the MSMEs and the big taxpayers, it is going to be a challenge if necessary changes are not incorporated in the accounting packages / ERP.

As the compliance requirements are stringent and mandatory, the taxpayers have to adapt to the new age technologies and start doing business. The adoption of technology helps them to concentrate on their core business areas rather than spending productive time on compliance work. We as professionals, have to guide the taxpayer accordingly and help them in the technology adoption. Things can be done without technology, but they will consume a lot of time and effort. As business is slowly moving from the unorganized sector to the organized sector, there will be some teething troubles, and we should join hands together for the transformation to happen smoothly.

Disclaimer

Any views or opinions represented above are personal and belong solely to the author and do not represent those of people, institutions or organizations that the author may or may not be associated with in professional or personal capacity unless explicitly stated. Any views or opinions are not intended to malign any religion, ethnic group, club, organization, company, or individual.

This article is published in Souvenir released in the Southern Regional Cost Convention held in Chennai in Nov 2019.