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October 1, 2020

E-Invoice Provisions relaxed for the month of October 2020

by facelesscompliance in GST, GST Circular Notification

E-Invoice Provisions relaxed for the month of October 2020

The recent Press Release of Central Board of Indirect Taxes and Customs dated 30th September 2020 has relaxed E-Invoice Provisions for the month of October 2020


The Government had in December 2019 prescribed that the GST Taxpayers having aggregate annual turnover more than Rs. 100 crores in any preceding Financial Year will be required to issue E-invoice for all the Business to Business (B2B) supplies, in the manner prescribed under rule 48(4) of the CGST Rules, 2017 w.c.f. P’ April 2020.

Further, it was also mandated under rule 48 (5) of the CGST Rules, 2017 that a B2B invoice or an export invoice issued by such a taxpayer, in any other manner, shall not be treated as an invoice. In March 2020, the date of implementation of c-invoice was extended to 1″ October 2020. Keeping in view the hardships faced by the taxpayers due to COVID-19 lockdown, in July 2020, it was further prescribed that the taxpayers having aggregate turnover of Rs. 500 Cr. and above only would be required to issue c-invoice w.c.f. 1″ October 2020.

It has been reported that even after more than 9 months of the first notification in this regard, some of these taxpayers having aggregate turnover of Rs. 500 Cr. and above are still not ready.

Accordingly, as a last chance, in the initial phase of implementation of c-invoice, it has been decided that the invoices issued by such taxpayers during October 2020 without following the manner prescribed under rule 48(4), shall be deemed to be valid and the penalty leviable under section 122 of the CGST Act, 2017, for such non-adherence to provisions, shall stand waived if the Invoice Reference Number (IRN) for such invoices is obtained from the Invoice Reference Portal (IRP) within 30 days of date of invoice.


The same is illustrated with an example: In case a registered person has issued an invoice dated 3″I October. 2020 without obtaining IRN but reports the details of such invoice to IRP and obtains the IRN of the invoice on or before 2″ri November, 2021 then it shall be deemed that the provisions of rule 48 (5) of the CGST Rules, 2017 arc complied with and the penalty imposabk under section 122 of the CGST Act, 2017 shall also stand waived. Relevant notifications would follow.

It may be noted that no such relaxation would be available for the invoices issued from 1″ November 2020 and such invoices issued in violation of rule 48(4) of the CGST Rules 2017 would not be valid and all the applicable provisions of CGST Act and Rules would apply for the said violation.

Notification No. 70/2020: Amendment has been made in earlier Notification No. 13/2020 dated 21st Mar’20 issued w.r.t E-Invoice in relation to followings to turnover

FY for which aggregate turnover is to be checked. Now, it is ‘any preceding FY from FY 2017-18 onwards’ instead of ‘a financial year’ meaning thereby that if the T.O of any taxpayer was more than Rs. 500 Crs in any  preceding FY from FY 2017-18 onwards then E-Invoice will be applicable.

Further, earlier the mandate to prepare E-invoice was for B2B transactions though by way of FAQ’s it was clarified that export invoices are also covered. Now, the same have been regularised by way of this notification adding the words ‘or for exports’ also after the words ‘ goods or services or both to a registered person.

Notification no 71/2020: Requirement of dynamic QR code for B2C invoices deferred till 1st of December 2020

Under rule 46 which prescribed mandatory particulars to be mentioned on the invoice, QR code having enabled IRN in case of B2B invoices shall be part of mandatory particulars of this rule.

iIn rule 48(4) which prescribe manner for issuing e invoice, power has been given to commissioner to exempt any registered person for issuing of e invoice for a specified period by way of notification.

In Rule 138A_ In case of e invoice transporter can produce IRN and QR code electronically for verification by Proper officer instead of physical copy of tax invoice.

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