Electronic Invoices Mandatory from 1 April 2020

The gist of the notifications is as under:

1.     A new sub-rule has been inserted to mandate issuance of electronic invoices by registered persons having an aggregate annual turnover in excess of INR100 crores. The requirement is for supplies made to a registered person only

2.     The aforementioned electronic invoice should mandatorily contain the following:

Ø  Particulars as contained in Form GST INV-01 after obtaining Invoice Reference Number (IRN)

Ø  The tax invoice shall also contain Quick Response (QR) code

3.     Further, where registered persons have a turnover in excess of INR500 crore and   make a supply to an unregistered person (B2C supplies), invoices shall contain the QR code

4.     The changes shall come into effect from 1 April 2020

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

It may be noted that for the purpose of e-invoice, ten Invoice Registration Portal (IRP) have been notified. The same shall be effective from 1 January 2020.

[Notification no 69/2019-Central Tax dated 13 December 2019]

Our comments

During the last few months, there were several news articles on this subject. Vide the above notifications, the Government has shown its intent to implement e-invoicing from the coming financial year. Also, ten IRPs have been notified from 1 Jan 2020 itself, which means the industry can initiate e-invoicing from 1 Jan 2020.

The industry should now gear up and use the voluntary three-month e-invoice generation

period effective 1 January 2020 and identify challenges/suggestions which can be represented before the Government.