Taxpayers who are required to issue Dynamic QR Code in case B2C supplies where their turnover is above ₹ 500 crores during any of the three financial years, relaxation is being provided and in case if they do not issue tax invoices with dynamic QR code there will be no levy of penalty under Section 125 of CGST Act 2017 till 30th Sep 2021.
This extension is being provided due to the on going pandemic. This is notified wide Notification No 28/2021 – Central Tax dated 30th June 2021.
Extract of the Notification
G.S.R. 450(E).—In exercise of the powers conferred by section 128 of the Central Goods and Services Tax Act, 2017 (12 of 2017) (hereafter in this notification referred to as the said Act), the Government, on the recommendations of the Council, and in supersession of notification of the Government of India in the Ministry of Finance (Department of Revenue), No. 89/2020 – Central Tax, dated the 29th November, 2020, published in the Gazette of India, Extraordinary, Part II, Section 3, Subsection (i), vide number G.S.R. 745(E), dated the 29th November, 2020, except as respects things done or omitted to be done before such supersession, hereby waives the amount of penalty payable by any registered person under section 125 of the said Act for non-compliance of the provisions of notification No.14/2020 – Central Tax, dated the 21st March, 2020, published in the Gazette of India, Extraordinary, Part II, Section 3, Sub-section (i), vide number G.S.R. 197(E), dated the 21st March, 2020, between the period from the 1st day of December, 2020 to the 30th day of September, 2021.
Due to the ongoing second wave of the Covid – 19 pandemic, there are a lot of restrictions imposed on the business and common person to curtail the spread of the virus. As a part of lockdowns or restrictions, the trade and industry cannot run the business full-fledged and causing a lot of hardships in the filing of returns or meet the compliance requirements. Keeping in view of all these, the Government has provided relaxation under GST in for wavier/part wavier of interest, late fee and extension of due date for filing of returns.
Notification No 8/2021 – Central Tax Dated 1st May 2021 – Reduction & wavier of Interest for delayed payment of taxes
Interest will not be applicable for the delay in filing of returns for the first 15 days, and from 16th day to 30th day, it will be charged at 9%, and after 30 days, the interest rate will be 18%, i.e., the normal rate. The above benefit will be applicable for the following class of persons for the months of April and May 2021
Taxpayers having aggregate turnover above ₹ 5 crores during the previous financial year
Taxpayers having aggregate turnover up to ₹ 5 crores during the previous financial year and filing GSTR – 1
Taxpayers having aggregate turnover up to ₹ 5 crores during the previous financial year and filing returns under QRMP (Quarterly Returns Monthly Payment) Scheme
Taxpayers who are availing of the Composition Scheme benefit
The above notification is a retrospective notification and is effective from 18th April 2021
Notification No 9/2021 – Central Tax Dated 1st May 2021 – Relaxation in Late fee
Levy of the late fee has been waived for the taxpayers who are filing GSTR – 3B
Late fee has been waived off for the first 15 days for taxpayers having aggregate turnover above ₹ 5 crores during the previous financial year
Late fee has been waived off for the first 30 days for taxpayers who are filing GSTR – 3B on a monthly basis and quarterly basis having aggregate turnover up to ₹ 5 crores during the previous financial year
The above notification is a retrospective notification and is effective from 20th April 2021
Notification No 10/2021 – Central Tax Dated 1st May 2021
The due date for filing of GSTR – 4 by composition taxpayers has been extended to 31st May 2021.
The above notification is a retrospective notification and is effective from 30th April 2021
Notification No 11/2021 – Central Tax Dated 1st May 2021
The due date 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 1st January 2021 to 31st March 2021 has been extended from 25th April 2021 to 31st May 2021.
Notification No 12/2021 – Central Tax Dated 1st May 2021 – Extension in filing due date for filing of GSTR – 1
The due date for filing of GSTR – 1 for the month of April 2021 has been extended to 26th May 2021.
Notification No 13/2021 – Central Tax Dated 1st May 2021 – Relaxation in matching
Relaxation in matching for the availing input tax credit for April 2021 has been provided, and the taxpayers have to do matching for the months of April and May together while filing GSTR – 3B for the month of May 2021.
Taxpayers who are filing returns under QRMP Scheme can file IFF (invoice furnishing facility) by 28th May 2021.
Notification No 14/2021 – Central Tax Dated 1st May 2021 – Relaxation in compliance proceedings due date
The time limits for the completion of compliance or any action by the tax authorities or any person which are falling between 15th April 2021 to 30th May 2021 has been extended in the following cases
a) completion of any proceeding or passing of any order or issuance of any notice, intimation, notification, sanction or approval or such other action, by whatever name called; or
b) filing any appeal, reply, or application or furnishing any report, document, return, statement, or other records, by whatever name is called.
The above extension is not applicable in the following cases
Related to Time of Supply
If the turnover of the composition taxpayer has crossed the threshold during this period
Section 25 – registration procedure
Section 27 – procedure-related to casual taxable person and the non-resident taxable person
Section 31 – Tax Invoice
Section 37 – provisions related to the filing of returns for outward supplies
Section 47 – provisions related to levy of late fee
Section 50 – provisions related to ley of interest
Section 69 – provisions related to power to arrest errant taxpayers
Section 90 – provisions related to Liability of partners of firm to pay tax
Section 122 – provisions related to penalties for certain offenses
Section 129 – provisions related to detention, seizure and release of goods and conveyance under transit
Section 39 – except for provisions related to sub-section (3), (4) and (5) related to TDS deductors, ISD and not resident taxpayers
Section 68 – provisions related to e-waybill
Provided that where, any time limit for completion of any action, by any authority or by any person, specified in, or prescribed or notified under rule 9 of the Central Goods and Services Tax Rules, 2017, falls during the period from the 1st day of May 2021 to the 31st day of May 2021, and where completion of such action has not been made within such time, then, the time limit for completion of such action, shall be extended up to the 15th day of June 2021;
We are in the world of New Normal due to the ongoing pandemic globally. Pandemic has resulted in disruptions and business strategy changes based on consumer preferences and budget allocations. The organizations have started the new financial years on 1st April 2020 in the lockdown period. None of the organizations have prepared or able to scale to the dynamic & ever-changing business environment. Time Never Stops, and History Repeats are the two common phrases we hear in our discussions in business circles. Come whatever may happen, organizations have to close their books of accounts for 31st March year. Closure of books in time and properly helps the organization mitigate the risks and take timely actions for the coming year to improve the top line and bottom line. What is required for increasing the top line and bottom line is a strategy on how to achieve it, and compliance is one of the strategies meant to achieve the same. As we all know, GST is a Business Reform, not tax reform; changing few business processes in the organization here and there can ensure productivity while safeguarding the organization from hefty penalties and late fees. Following a structured process will ensure to minimize the same and at the same time be in good books of the tax authority and the suppliers. Professionals and taxpayers are required to complete the following before filing the GSTR – 1 and GSTR – 3B for March 2021 by 11th of April 2021 and 20th of April 2021 ( for few taxpayers, it will be 22nd of April or 24th of April if their turnover is less than ₹ 5 cores based on the state they are located).
Reconciliation of Outward Supplies
Reconciliation of Inward Supplies
Reconciliation of Related Party Transactions
Issue of Pending Debit/Credit Notes
Reversal of ITC arising out of pandemic
Reconciliation of Outward Supplies
A series of reconciliations have to be done while filing the returns for March 2021 if the reconciliations have not been done while filing monthly and quarterly returns.
Verify the following for the correctness of the data in return filing
Taxable Supplies, Exempted Supplies are reported correctly
Non-GST supplies are reported correctly
Supplies to deemed exporters are reported correctly at lower tax rates
Supplies to notified agencies at a lower rate are reported correctly
All outward supplies transactions are reported correctly in the Sales Register
Ensure that e-invoices are issued wherever required if applicable
Ensure and validate that the GSTINs of the customers are entered correctly and reported
Ensure and validate that no GST is charged for transactions within the state having the same GSTINs
Ensure that all the debit and credit notes are issued as per the provisions of GST
Ensure and verify that all the liability entries are passed in the books of accounts
Complete the following reconciliations before the filing of the March GST Returns
Reconcile between the GSTR – 1 data and the Sales Register
Reconcile between GSTR – 1 and GSTR – 3B
Reconcile between GSTR -3B and Sales Register
Reconcile the data for the HSN summary being reported in monthly GSTR – 1
Reconcile e-waybill data with GSTR – 1 data, and if there are any differences, it is worth making a reconciliation statement and preserve it for future references.
Reconcile the e-invoices reported in the GSTR – 1 with the e-invoices generated
Reconcile between the Liability Ledgers on GST portal with the
The beginning of the year started with lockdown, and it has resulted in a lot of delays and cancellations of orders. Wherever there is a commercial element missing and open, try to close all such cases by the issue of debit and credit notes. Credit Notes have to be issued before the due date of filing of GSTR returns for the month of September or filing of Annual Return, whichever is earlier.
Section 37 (3), First Proviso
Provided that no rectification of error or omission in respect of the details furnished under sub-section (1) shall be allowed after furnishing of the return under section 39 for the month of September following the end of the financial year to which such details pertain, or furnishing of the relevant annual return, whichever is earlier.
If any excess tax is paid for the said period through GSTR – 3B, then the same should be reduced from the GST liability in March 2021, reducing the cash outflows. Also, please maintain a reconciliation statement for the same for future reference.
2.Reconciliation of Inward Supplies
One of the major features and business-friendly measures in GST is the availability of seamless input tax credit. Though it is a piece of soothing music to the business’s ears, it comes with a set of stringent measures like if input tax credit has been availed wrongly or excess amounts or claiming it if the supplier has not filed returns. Given all these, availing of the input tax credit process and claiming correctly becomes crucial for the business.
One of GST rollout’s major benefits for the trade and industry is the availability of input tax credit seamlessly across the supply chain cycle. Though input tax credit is available, certain restrictions are available, and they are given in Section 16, Section 17(5), and in the corresponding rules.
Section 16(4) A registered person shall not be entitled to take input tax credit in respect of any invoice or debit note for supply of goods or services or both after the due date of furnishing of the return under section 39 for the month of September following the end of financial year to which such invoice or invoice relating to such debit note pertains or furnishing of the relevant annual return, whichever is earlier.
Before doing the reconciliation, ensure to complete the following tasks
Update the purchase register for the entire year and ensure all the transactions are updated in it.
Verify that e-invoices are received from all the suppliers to whom it is applicable; else, it will not be considered a tax invoice and not eligible to claim the input tax credit.
Verify and ensure that all the original copies of the tax invoice are available
Verify and ensure that the goods and services are received before availing of the input tax credit
Verify and ensure that all the credit and debit notes are updated in the system and accounted
Verify and ensure that if any debit or credit notes are required to be issued by the supplier are issued, filed by the supplier in his returns and also accounted in the books
Verify and ensure that RCM applicability on inward supplies is identified and accounted for, and paid.
Verify and ensure that input tax credit is availed only on eligible inward supplies only
Verify and ensure that input tax utilization entries passed in the books of accounts
(b) the following supply of goods or services or both—
food and beverages, outdoor catering, beauty treatment, health services, cosmetic and plastic surgery, leasing, renting or hiring of motor vehicles, vessels or aircraft referred to in clause (a) or clause (aa) except when used for the purposes specified therein, life insurance and health insurance:
membership of a club, health and fitness centre; and
(c) works contract services when supplied for construction of an immovable property(other than plant and machinery) except where it is an input service for further supply of works contract service;
(d) goods or services or both received by a taxable person for construction of an immovable property (other than plant or machinery) on his own account including when such goods or services or both are used in the course or furtherance of business.
(h) goods lost, stolen, destroyed, written off or disposed of by way of gift or free samples; and
Apart from ensuring the steps mentioned above are completed and the do the reconciliation
Complete the following reconciliations
Reconcile between GSTR – 2A / 2B with Purchase Register
Reconcile between GSTR -2A /2B with GSTR – 3B
Reconcile between GSTR-3B with Purchase Register
Reconcile the ITC Ledger on GST portal with the various ledger accounts
Rule 69 – Matching
The following details relating to the claim of input tax credit on inward supplies including imports, provisionally allowed under section 41, shall be matched under section 42 after the due date for furnishing the return in FORM GSTR-3-
Goods and Services Tax Identification Number of the supplier;
Goods and Services Tax Identification Number of the recipient;
invoice or debit note number;
invoice or debit note date; and
3. Reconciliation of Related Party Transactions
In multiple instances, related parties are not accounted for properly, or returns are filed incorrectly. This results in a lot of tax litigation or reversal of input tax credits through discharge of liability. Though there is no loss to the exchequer, it is not as per the law’s provisions, and the taxpayer cannot amend the returns if they have claimed wrongly.
It is recommended to verify all such transactions if there are any related party transactions and rectify the same in the March months returns. This process will ensure no loss of input tax credit, excess payment of taxes, which impacts the organization’s bottom line. This will also eliminate litigation and save time and effort.
The above process is not required if the taxpayers reconcile their data before filing their monthly returns
4. Issue of Pending Debit/Credit Notes
In a going business concern, there will always be issues and challenges in the supply chain. The supply chain challenges could be damages or breakages in transit or delay in shipments or receipt of goods, or receipt of inferior quality or different ones from the ordered—all these results in some price negotiations or others. In GST, only the supplier of goods or services can issue a debit note, and the recipient cannot unilaterally issue a debit note or credit note on the supplier.
As the above case results in price negotiation, there will always be a delay in the process, and as it is the year-end, it is recommended to clear all such pending issues. A rigorous follow-up with the vendors is required, backed by documentation.
Another case could be on account of reconciliation, there could be some suppliers who must have missed filing their returns, or their registrations have been canceled; in all such cases where the supplier has not filed the returns, a credit note should be requested to be issued to compensate the loss of input tax credit. If the supplier does not issue a credit note and the payment is already made, then the taxpayer cannot do anything but reverse the input tax credit with interest at the rate of 24%; payment of interest will be an additional loss to the taxpayers. To avoid such cases, before the payment release, it is recommended to complete the reconciliation process or withhold the tax amount until the supplier files the GST returns. This process will ensure that there is an impact on the bottom line.
Similar could be the case in the case of outward supplies. Also, it is recommended to issue debit or credit notes before the 31st of March 2021.
Section 34(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 September 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:
Though there is no time limit for the issue of Debit Note but is advised to issue the same as the same will minimize the pending issues, the issue of debit notes brings is additional cash into the system, which has become scarce due to the business disruptions on account of the pandemic.
5.Covid Impact on GST
The pandemic has impacted every business directly or indirectly. The impact is on the sales front, profits front as well on the operations and employee front. As the lockdowns have been announced to curtail the spread of the deadly virus, many manufacturers and service providers have impacted their businesses.
If any spoilage/wastage of raw materials or work in progress, the same is being debited to the Profit and loss account simultaneously. If any input tax credit has been availed, the same has to be reversed and observed in the profit and loss account.
If any goods have been expired due to the lockdown, the same is being written off to the profit and loss account. Similarly, the input tax credit has to be reversed if any availed.
If the customers have returned the goods and the same could not be used, were scrapped or destroyed for not being used, the input tax credit has to be reversed on such goods.
If the scrapped goods are sold at a nominal rate, then input tax credit need not be reversed as it is sold as scrap, and GST is paid on it as per one school of thought.
The pandemic has also resulted in a delay in payments. Identify if the suppliers are paid within 180 days; if not, the input tax credit must be reversed on the amounts due from one hundred and eighty-first day onwards.
If any return of the goods by the customers or dealers or distributors, issue the credit notes immediately without further delay. It will be a challenge in financial reporting if issued after 1st April 2021.
If the advance is received from the customers and service is not being provided due to the lockdowns, advance received treatment becomes crucial in GST. The possible scenarios and treatment under GST
If the advance is returned in the same month, then no need to account for GST on receipt of the advance. Verify and validate all such advance receipts, and if GST is not paid, please pay interest on it if the invoice is issued in the subsequent months.
If the invoice is not issued till 31st March and service is not provided, validate and verify if GST is paid on the advance receipt along with the interest
If an amount is partially returned in the subsequent months and service is not provided, validate and verify if GST is paid on advance receipt if not account it and pay along with interest
The pandemic has also resulted in a delay in payments. Identify if the suppliers are paid within 180 days. If not, the input tax credit must be reversed on the amounts due from one hundred and eighty-first day onwards.
If any credit notes are required to be issued for the delay in service, complete the activity before filing GST Returns for March; else, reconciliation statements have to be prepared to explain to various stakeholders.
If any debit notes have to be issued for price variations, the activity must be completed before the GST Returns filing for March 2021; else, reconciliation statements must be prepared to explain to various stakeholders.
The points mentioned above are indicative and may vary from taxpayer to taxpayer. It is also recommended to address the following points before the filing of the March return
Inputs sent on job work if not returned within the stipulated period; tax invoice has to be issued
Avail of the input tax credits if any is missed out
There is an exemption for reporting input tax credit by classification for the first two years only; the taxpayers must classify and claim input tax credit accordingly. If not done, prepare a reconciliation statement and validate that the same match the input tax credit claimed in GSTR – 3B.
Verify If any employee gifts above Rs 50,000 on which tax liability has to be paid
Verify if any input tax credit has to be reversed for the goods given without any consideration
Verify if any shortages or damage to stock on which input tax credit has been claimed? If any such items are there, reverse the input tax credit
Validate the input tax credit reversed on common inputs for taxable and exempted supplies being reversed
Verify input tax credit has been reversed on a pro-rata basis on capital goods from one state to another state
Verify the financial credit notes and debit notes issued according to the l provisions; else, issue GST Credit / Debit Notes.
File all the relevant returns as per applicability and complete the reconciliations
Verify if all the customers who have to file GSTR – 7 & 8 have filed their returns and accepted the same, this will save on the cash outflows.
Wherever possible, if any ITC has to be reversed or tax has to be paid, account for it and discharge it through GSTR – 3B.
Verification of the above tasks is a time-consuming process, and it is recommended to start the process ASAP and ensure that no input tax credit benefit lapses. No removal of difficulties order has been issued for availing input tax credit for an extra period on account of a pandemic-like situation.
During the first three years after the rollout of GST, there was an option for corrections using the GSTR – 9 for liability. The same is being withdrawn based on the Finance Bill 2021, yet to be notified; if this is the case, there is no room left for the taxpayers for rectification. The wrongdoings can be seen only during the audit or scrutiny by the department officers over a period of time. By that time, the penalty amount along with interest also is going to be increased multi-fold. To avoid such challenges, it is highly recommended to follow the above steps before filing the returns for March 2021.
To avoid all the challenges, the return filing data should be captured in the accounting or ERP system accordingly. Wherever possible, automation should be introduced to minimize human efforts and automate the process of data entry and reconciliations. Let’s not forget that GST is a business reform and not tax reform.
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 within a 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.
The new financial year starts tomorrow, and there are many activities to be done as per year ending for the organization. Apart from those year-ending activities, some changes must be done from 1st April 2021 with respective compliances from GST, Income Tax & MCA purposes. These changes are statutory for some and for some in improving the ease of doing business. Key changes required to be carried out from 1st April in are listed below
New document series
As per provisions of Goods and Service Tax, the taxpayers must maintain unique number series for the documents being issued by them for every financial year. The document sequence has to be re-set for some accounting packages. It is automatic in some accounting packages, cases where it has to be done manually; the taxpayers have to be careful and complete this step before creating any new transactions for the new financial year. Document Sequence/numbering has to be changed for the following documents in GST
Bill of Supply
Tax Invoice Cum Bill of Supply
2. HSN Code
There is also a change in the HSN code requirement under GST to be printed on the Tax Invoice. The following are the changes
For taxpayers how are having turnover above ₹, five crores are required to show six digits
For taxpayers whose turnover is below ₹, five crores are required to show four digits in business-to-business transactions. In the case of Business to Customer Transactions, it is optional.
The taxpayers have to make necessary changes for the Item master if not updated with the latest provisions.
It is recommended to make changes for the item master with eight digits as it will be applicable in the near future, and changing master data frequently is not advised. Moreover, it is time-consuming and unproductive work.
e-invoice is required to be issued by taxpayers whose aggregate turnover is above ₹ 50 crores during the last three years from 1st April 2021.
It is recommended to make changes to the accounting or ERP system to address the above change.
If the taxpayer does not issue an e-invoice, is it not considered a tax invoice, and the recipient cannot take input tax credit at all.
It can be implemented using any of the four methods
Application Program Interface (API)
Secure File Transfer Protocol (SFTP)
For adopting any of the above methods, the taxpayers can approach any of the GST Suvidha Providers (GSPs or Application Service Providers (ASPs).
Even though the taxpayers will be using the Bulk or Single JSON upload for the generation of e-invoice from the department portal or ASP/GSP solution, the same will not be integrated with the Accounting/ERP system; this may pose a challenge in the future. It is strongly recommended to update the Accounting/ERP system with e-invoice details for future references.
Letter of Undertaking is required to be taken by taxpayers who are making Zero Rated Supplies, and a new one has to be obtained before 1st April 2021.
It is recommended to take the same at the earliest, or it may impact your outward supplies accordingly.
5. Accounting package with audit trail and edit log
As per the latest notification from the Ministry of Corporate Affairs, all companies using accounting packages have to ensure that there is an audit log in the accounting package with the edit log.
Companies have to ensure that they are enabling the same if they maintain the same or request their accountant or CA to do the same.
There is a difference between the audit trail and edit log, in case of audit trail only Who is Who information is captured and in case of Edit log the date elements changed is also captured for future reference.
6. Change in Income Tax Rates – TDS & TCS
Due to the pandemic and lockdowns, the Government has announced a reduction in tax rates up to 31st March 2021 for some sections, and now from 1st April, the new rates or actual rates will be applicable.
It is recommended to verify and enter the new TDS / TCS rates in the masters with the effective date to maintain the audit trail as per MCA notification. In case of shot, deductions of TDS or recovery of TCS penal provisions are applicable.
The above listed are major changes required to be carried out and same may vary from each taxpayer based on his nature of business and turnover. The taxpayers should always remember one thing, cost of non-compliance is a costly affair compared to the cost of compliance. Wherever required the taxpayers should take professional advice and not relay in information available in public domain to their best interests.
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 within a 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.
Dynamic QR (Quick Reference) code is required to be shown on all Business to Customers Tax invoices issued by a registered taxable person whose turnover exceeds rupees five hundred crores during any of the last three financial years.
Is there any difference between the QR code issued for e-invoice and the dynamic QR code?
Yes, there is a difference. Dynamic QR code is issued by taxpayers having turnover above rupees five hundred crores during any of the last three years for business-to-customer transactions. QR code for e-invoice is issued for a taxpayer in relation to business-to-business transactions.
2. From when is dynamic QR Code is applicable?
Initially, a Dynamic QR code is required to be issued from 1st of April 2020 wide notification number 72/2019 – Central Tax dated 13th December 2019. It got postponed to 1st of October 2020 wide notification number 14/2020 central tax, dated 21st March 2020, due to the pandemic-like situation and business were not ready to implement the same technologically. The same got postponed to 1st Dec 2020 wide notification number 71/2020 – central tax dated 1st Dec 2020.
As part of providing relief to the taxpayers, notification number 89/2020 – central tax dated 29th Dec 2020 issued waving of penalty under Section 125 of the CGST Act 2017 from 1st December 2020 to 31st march 2021 in case if the taxpayers’ issues tax invoices without dynamic, quick reference code for business-to-customer transactions.
From 1st of April 2021, all taxpayers having aggregate turnover above rupees five hundred crores must issue dynamic, quick reference code for business to customer transactions.
3. Why did the Government introduce the Dynamic Quick Reference Code?
The Government has issued the dynamic, quick reference code to track the invoices and payments received against such invoices.
4. What should be shown in the dynamic QR code?
The dynamic QR code should show the following information
Supplier GSTIN number
Supplier UPI ID
Payee’s Bank A/C number and IFSC
Invoice number & invoice date,
Total Invoice Value and
GST amount along with breakup, i.e., CGST, SGST, IGST, CESS, etc.
The dynamic QR code generated should have the facility for the customer to make digital payment.
5. Dynamic QR codes should be generated for which documents?
Dynamic QR code has to be generated for only tax invoices only as per notification number 72/2019 – Central Tax dated 13th December 2019.
6. In the case of exports, the overseas customer does not have a GSTIN number. Dynamic QR code has to be issued for export transactions?
No, a dynamic QR code is not required to be issued for the export invoices as e-invoice is being already issued for such transactions.
7. In multiple instances, we could see the suppliers or the retailers displays the QR code for enabling the payment by the customers. In such cases, also the Dynamic QR code has to be printed on the tax invoice?
As long as the supplier maintains the payment track, issuing tax invoices with dynamic QR codes for Business to customer transactions is not required.
The payment reference should be linked to the tax invoice/transaction id, date, time and amount of payment, mode of payment like UPI, Credit card, Debit card, online banking etc.
8. There are instances where the customers pay the retailers in cash; even in such cases, dynamic QR code has to be provided?
No, if the customer opts to pay the invoice in cash, it is not required in such cases, but the retailer has to maintain the cross-reference of the same.
9. In some instances, we come across where the retailer collects the payment before the issue of tax invoice, like sharing the OTP in case of Paytm or making payment through a link. Even in such cases, the retailer has to issue a Dynamic QR code?
In such cases, the retailer is not required to issue the tax invoice with a dynamic QR code as the payment is collected before the invoice is issued and cross-reference for the payment and invoice already exist.
10. In case of cash on delivery by the e-commerce operators or supplies made through e-commerce operations, does the tax invoice issues should have the Dynamic QR code?
In the case of supplies through e-commerce operators by e-commerce operators for cash on delivery termed as COD basis, a Dynamic QR code must be issued and printed on the tax invoice.
The Government has provided multiple postponements for the Dynamic QR code rollout, and now it is mandatory to be issued from 1st April 2021. If the taxpayers do not follow the same, then the department officers can issue penalty under Section 122 and Section 125 of the CGST Act 2017. Going by the trend of issue of e-invoice where the threshold has been reduced from rupees five hundred crores as on 1st Oct 2020 to rupees 50 crores from 1st April 2021, the threshold for the issue of dynamic QR code can also be reduced going forward. Based on past experiences, the taxpayers should gear up for the same even though it is not applicable as on date.
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.