TaxPro GSP - eInvoiceAPI
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 (c) Chartered Information Systems Pvt. Ltd., 2018

General Questions on e-invoice system

 
Generic questions on e-invoice
1.     Will businesses now be required to generate e-invoices on the GST portal or the e-invoice portal or the IRN portal?
a.     No. 
b.     Businesses will continue to generate e-invoices on their internal systems – whether ERP or their accounting / billing systems or any other application.
c.     The e-invoicing mechanism only specifies the invoice schema and standard so as to be inter-operable amongst all accounting/billing software and all businesses.
2.     Please clarify whether there the current e-invoice schema is for the invoice to be issued by Govt or has to be maintained in the IT system by the tax payer?
a.     The invoice schema has to be maintained and invoices generated using this schema by the taxpayer himself.
b.     The GST portal or Invoice Registration Portal (IRP) will NOT provide facility to generate invoices. IRP is only to report the invoice data.
c.     The ERP or accounting billing software or any other software tool to generate e-invoice of the seller shall only generate invoices.
3.     Will there be separate invoice formats required for Traders, Medical Shops, Professionals and Contractors?
a.     No.
b.     Same e-invoice schema will be used by all kinds of businesses. The schema has mandatory and non-mandatory fields. Mandatory field has to be filled by all taxpayers. Non-mandatory field is for the business to choose. It covers all most all business needs and specific sectors of business may choose to use those non-mandatory field which are needed by them or their eco-system.
4.     How long will the e-invoice generated would be available at the Government portal?
a.     It is again clarified that the e-invoice will not be generated at the GST portal.
b.     It will be generated only at the seller’s system – whether ERP or the accounting/billing system/other software tools of the seller.
c.     It will be uploaded into the GST ANX-1 only once it has been validated and registered by the invoice registration system.
d.     After it has been validated and is available in the ANX-1, it will be visible to the counter party in his ANX 2.
e.     Thereafter it will be visible and available for the entire financial year and archived.
f.     As far as data on IRP is concerned, it will be kept there only for 24 hours.
5.     While all businesses generate invoice at the same time, how will the server react?
a.     The businesses will generate the invoice at their system and hence that will not impact the servers of IRP.
b.     The capacity of the system at IRP shall be built so as to handle the envisaged loads of simultaneous upload based on data reported in GSTR1 for last two years.
c.     Subsequently, multiple invoice registrars will be made available that will be able to distribute the load for invoice registration.
6.     Is it possible to auto populate fields of the e-invoice based on credentials entered?  That way it can minimize data entry errors.
a.     Since the invoice generation is to happen at the business end, this can be built into the ERP or invoicing system of the seller. Most of such software provide this facility in the name of item master, supplier master, buyer master etc.
7.     Will it be possible to add transporter details as well?
a.     No.
b.     The transporter details must be entered in the E-Way bill system only.
Contents of e-invoice
1.     There are certain fields today which are optional and some mandatory.  How are these to be used?
a.     The mandatory fields are those that MUST be there for an invoice to be valid under e-Invoice Standard.
b.     The optional ones are those that may be needed for the specific business needs of the seller/business. These have been incorporated in the schema based on current business practices in India.
c.     The registration of an e-invoice will only be possible once it has ALL the mandatory fields uploaded into the Invoice registration Portal (IRP).
d.     A mandatory field not having any value can be reported with NIL. 
2.     What is the maximum Number of line items supported by e-invoice?
a.     The maximum number of line items per e-invoice is 100.
3.     Does the e-invoice schema provide the maximum length of the various fields in the schema?
a.     Yes.
b.     Each field specification has been provided with the type of characters that are to be entered and its length as well.
4.     What will be the threshold requirement for E-Invoicing applicability?
a.     This will be notified by the Government at the time of rollout.
b.     As already mentioned above, the rollout of the e-invoice mechanism will be in phases.
5.     Will the e-invoice have columns to show invoice currency?
a.     Yes, the seller can display the currency.  Default will be INR.
6.     Whether the IRN is to be captured in the Supplier’s ERP?
a.     The IRN (hash) will be generated by GST System using GSTIN of supplier or document creator, financial year and the unique serial number of the document/invoice. The IRN can also be generated by the seller.
b.     The serial number of invoice will be unique for a GSTIN for a Fin Year and the same has to be captured by Supplier’s ERP.
c.     Supplier has to keep the IRN against each of its invoice. It will be advisable to keep the same in the ERP as invoice without IRN will not be a legal document.
7.     Whether e-invoice generated is also required to be signed again by the taxpayer?
a.     Not mandatory. However, if a signed e-invoice is sent to IRP, the same will be accepted.
b.     The e-invoice will be digitally signed by the IRP after it has been validated. The signed e-invoice along with QR code will be shared with creator of document as well as the recipient.
c.     Once it is registered, it will not be required to be signed by anyone else.
8.     Whether the facility of adding discount amount at line item-level would be mandatory in nature?
a.     The e-invoice has a provision for capturing discount at line item level. 
b.     The discounting at line item level is to be mentioned only when and if it is applicable in the particular transaction.
9.     Can the seller place their LOGO in the e-Invoice Template?
a.     There will NOT be a place holder provided in the e-invoice schema for the company logo.
b.     This is for the software company to provide in the billing/accounting software so that it can be printed on his invoice using his printer. However, the Logo will not be sent to IRP. In other words, it will not be part of JSON file to be uploaded on the IRP.
10.     There should be a space provided for the QR code to be placed.
a.     The QR code will be provided to the seller once he uploads the invoice into the Invoice Registration system and the same is registered there.
b.     Seller can at his option may print the same on Invoice.
11.     Will we be able to provide the address and bill-to party and PAN details in the e-invoice?
a.     Yes.
b.     It will be possible to provide all these details in the placeholders provided in the schema.
12.     Would the Supplier be allowed to issue his own invoice and if yes, will the Invoice number and IRN be required to be mentioned?
a.     Yes, the supplier will issue his own system’s invoice, in the standard e-invoice schema that has been published. Invoice number is a mandatory item under GST and hence for e-invoice.
b.     IRN (Hash) can be provided after the e-invoice has been successfully reported to the IRP. E-Invoice will be valid only if it has IRN.
13.     The current e-invoice template provides for total discount for all the products or services. Will this be possible in the e-invoice?
a.     Yes.
b.     There is a mechanism and placeholders to provide discounting on item level as well as total discounts on the invoice value.
14.     Will there be an option for linking multiple invoices in case of debit note/ credit note?
a.     Yes, it will be allowed to link the credit/debit notes as hitherto fore.
15.     Will the e-invoice schema cater to reverse charge mechanism?
a.     Yes.
b.     E-invoice system has a reverse charge mechanism reporting as well.
 
Method of Reporting e-Invoice to GST System
1.     In addition to the above, we understand that electronic invoice which will be uploaded on GST portal will be authenticated and IRN will be allocated for each e-invoices generated.
a.     Yes, the e-invoice will be authenticated with the digital signature of the IRP (invoice registration portal).
b.     IRN (Invoice Reference Number) will be the hash generated by the IRP. 
c.     The registered invoice will be valid to be used by the business.
2.     Will it be possible for bulk uploading of invoices for e-invoicing as well?
a.     Invoices have to be uploaded on IRP one at a time.
b.     The IRP will be able to handle a large sequence of invoices for registration and validate them. Essentially bulk upload will be required by large taxpayers who generate large number of invoices. Their ERP or accounting system will have to be designed in such a way that it makes request one by one. For the user, it will not make any difference.
3.     Will the requirement for such invoices to be authenticated by the supplier using a digital signature/signature be done away with?
a.     The seller will need to upload the e-invoice into the Invoice Registration Portal.
b.     The signing of e-invoice by seller is not mandatory.
4.     Will there be a time limit for e-invoice uploading for registration?
a.     Yes, that will be notified by the Government.  Without registration of e-invoice the same will not be valid. Required changes will be made in the law.
b.     Once uploaded to the invoice registration portal (IRP), it will be registered immediately, on real-time basis.
5.     Will it be possible to allow invoices that are registered on invoice registration system/portal to be downloaded and/or saved on handheld devices?
a.     Yes.
b.     IRP System after registering the invoice, will share back digitally signed e-invoice for record of supplier. It will also be sent to the email address of recipient provided in the e-invoice.
6.     Will it be possible to print the e-invoice?
a.     Yes.
b.     It will be possible for both the seller as well as the buyer to print the invoice, using the QR code as well as signed e-invoice returned by the Invoice Registration Portal (IRP).
 
Amendment/cancellation of e-invoice
1.     Whether e-invoices generated through GST system can be partially/fully cancelled?
a.     E-Invoice can’t be partially cancelled. It has to be fully cancelled.
b.     The e-invoice mechanism enables invoices to be cancelled. This will have to be reported to IRN within 24 hours. Any cancellation after 24hrs could not be possible on IRN, however one can manually cancel the same on GST portal before filing the returns.
2.     How would amendments be allowed in e-invoice?
a.     Amendments to the e-invoice are allowed on GST portal as per provisions of GST law. All amendments to the e-invoice will be done on GST portal only.
Relationship with e-way bill
1.     With the introduction of e-invoices, what are the documents need to be carried during transit of goods?
a.     For transportation of goods, the e-way bill will continue to be mandatory, based on invoice value guidelines, as hitherto fore. This aspect will be notified by the Government when this mechanism will be notified.
Export/Import
1.     Please clarify whether exports would require e-invoice compliance.
a.     Yes.
b.     The e-invoice schema also caters to the export invoices as well. The e-invoice schema is based on most common standard, this will help buyer’s system to read the e-invoice. 
2.     Does the e-invoice allow the declaration of export invoices/ zero rated supplies?
a.     Yes.
b.     It allows the declaration of export invoices / zero rated supplies.
Others
1.     What will be the workflow of the end to end e-invoice mechanism?
a.     The end to end workflow will be provided by at the time of rollout of the e-invoice system.
2.     Will the industry be provided sufficient time for preparation?
a.     Yes.
b.     The e-invoice mechanism is expected to be rolled out in phases from 01st Jan 2020 on voluntary basis.
c.     Initially, the e-invoice mechanism will be allowed for tax payers above a certain turnover or above a certain invoice value or also to volunteers.
d.     Subsequently, it will be enabled for all tax payers in a phased step-wise manner.
e.     Details of these will be published subsequently.