GST gets a facelift, E-Invoicing mandatory from April 1st, 2020

During the last few months there were several media reports relating to the electronic invoice (‘e-invoice’) in the GST law. The e-invoice system will first be rolled out, on a voluntary basis, from January 1st 2020 for the business houses with an annual turnover of more than INR 500 crore and for the business houses with an annual turnover of more than INR 100 crore from February 1st 2020.

Recently, the Central Board of Indirect Taxes and Customs has issued various notifications^[1] for compulsory issuance of electronic invoice (‘e-invoice’) by a registered person having turnover in excess of INR 100 crore for all B2B supplies. Further, Quick Response Code (QR Code) is mandatory for taxpayers having turnover above INR 500 crore in B2C segment.

Given below is a summary  of the notifications:

1. New sub-rule (4) has been inserted to Rule 48 of the CGST Rules, 2017 for compulsory issuance of e-invoice by registered person having aggregate annual turnover in excess of INR 100 crore. The requirement is for supplies made to a registered person only. It shall be effective from 1 April 2020.
2. The e-invoice should mandatorily contain the following:
   • Particulars as contained in Form GST INV-01 after obtaining Invoice Reference Number;
   • The tax invoice shall also contain QR Code
3. For the purpose of e-invoice, ten (10) Invoice Registration Portal have been notified. It shall be effective from 1 January 2020.
4. Where registered person having turnover in excess of INR 500 crore, makes supply to an unregistered person (i.e. B2C supply) then invoices shall contain QR Code.

Further, where the registered person is paid via the application of Dynamic QR Code made available to the recipient through a digital display, such invoice containing cross reference of the payment via the Dynamic QR Code shall be deemed to meet the criteria. It shall be effective from 1 April 2020.

1. Notification nos. 68, 69, 70, 71 and 72 / 2019 - Central Tax, dated 13 December 2019