1. Who is required to Generate E-invoice?
- Wide Notification No. 13/2020–Central Tax dated 21st March, 2020, amended from time to time, every registered person who had aggregate turnover in excess of INR 500 Crores during any preceding Financial year from 2017-18 onwards is required to generate e-invoice w.e.f. 1st October, 2020.
- Further, every registered person having aggregate turnover in excess of INR 100 Crores during any preceding Financial year from 2017-18 onwards is required to generate e-invoice w.e.f. 1st January, 2021.
|Registered Person for Einvoice||When to Start|
|Registered person having aggregate turnover in excess of INR 500 Crores||1st October 2020|
|Registered person having aggregate turnover in excess of INR 100 Crores||1st January 2021|
2. How to generate e-invoice?
Every such person shall prepare his invoice and shall obtain the Invoice Reference Number (IRN) from Invoice Registration Portal (IRP) for such invoice and such IRN is also known as “E-Invoices”.
3. Entitled exempted from generating e-invoice?
However e-invoicing shall not be applicable to the following categories of registered person, whether or not their turnover exceeds the limit, as notified in CBIC Notification No. 13/2020-Central Tax:
- An insurer or a banking company or a financial institution, including an NBFC.
- A Goods Transport Agency (GTA).
- A registered person supplying passenger transportation services.
- A registered person supplying services by way of admission to the exhibition of cinematographic films in multiplex services.
- An SEZ unit (excluded via CBIC Notification No. 61/2020 – Central Tax).
4. Auto-population of e-invoices in GSTR-1
- Details of such e-invoices shall be auto populated in respective tables of GSTR-1 of supplier and same can be downloaded in Excel sheet.
- For taxpayers who were required to generate e-invoice with effect from 1st October, 2020, due to technical glitches, the auto population of e-invoicing data into GSTR-1 for the month of October, 2020 and November, 2020 got delayed.
- Therefore, GSTIN advised to file GSTR-1 for October 2020 and November, 2020 by the due date without waiting for auto-population of data.
- Details of e-invoices for October, 2020 and November, 2020 started auto-populating in GSTR-1 from 1st Week of December and got available by 13th December, 2020.
- For December 2020, auto-population of e-invoices had started from December 3rd 2020.
5. Procedure of auto-population of e-invoices in GSTR-1
- The data in GSTR-1 is now available on T+3 day basis (Transaction date + 3 days), i.e. for example, the data for e-invoices uploaded on 15th December 2020 then the same would be visible in GSTR-1 on 18th December 2020.
- The auto population of e-invoice data into GSTR-1 is based on the date of document as reported to IRP.
For example, a document dated 30th December 2020 is reported to IRP on 3rd January, 2021. If GSTR-1 for December, 2020 is not filed, then the details of that document will be available in the tables of GSTR-1 pertaining to December, 2020.
However, if the GSTR-1 for December was already filed by that date, then, the details of such document will be made available in the consolidated excel file downloadable from GSTR-1 dashboard (with error description as ‘Return already filed’). The taxpayer may thereupon take necessary action.
6. Auto-population of e-invoices in GSTR-2A /2B/4A/6A
The invoices for which e-invoices have been generated, details of such e-invoice has started auto-populating in following forms as well:
- GSTR-2A (Auto-populated details of Inward Supply) of the recipient.
- GSTR-2B (Auto-drafted ITC statement of the recipient.
- GSTR-4A (Auto-populated Details of inward supply by a composition dealer) of the recipient.
- GSTR-6A (Auto-populated details of inward supply by Input Service Distributor).
7. Invoices not auto-populated in GSTR-1
However the following e-invoices with commonly observed issues are not auto-populated in the tables of GSTR-1. However, such invoices are available in the consolidated Excel file, and can be downloaded from the GSTR-1 dashboard:
- Supplier is found to be of type Input Service Distributor (“ISD”)/ Non-resident taxable Person (NRTP)/ Tax Collected at Source (“TCS”)/ Tax Deducted at Source (“TDS”).
- Supplier is found to be a composition taxpayer for that tax period.
- Document date is prior to Supplier’s/Recipient’s effective date of registration.
- Document date is after Supplier’s/Recipient’s effective date of cancellation of registration.
- Invoices reported as attracting “IGST on Intra-state supply” but without reverse charge.
8. Issues to be taken care of while generating e-invoice
In a few cases, details of e-invoices are not processed by the system due to structure issues and therefore, such invoices fail to auto-populate in GSTR-1. Therefore, taxpayers are advised to take care of following errors and should avoid the same while generating e-invoices:
- Serial number of item shall not be reported as ‘0’
- white space provided for place of supply(POS), POS is “8”, registered person should enter either “8” or “08”
Further, GSTIN has clarified that the auto-population of details from e-invoices into GSTR-1 is only a facility for the taxpayers. It is the responsibility of taxpayer to verify the propriety and accuracy of the amounts and all other data in each field, especially from the perspective of GSTR-1 and file the same, in the light of relevant legal provision
The Taxpayer has advised to verify the documents auto populated in GSTR-1 tables and in excel on below aspects:
- All documents reported to IRP are present in excel.
- Status of each e-invoice/IRN is correct
- All the details of document are populated correctly