Government has decided to impose a time limit on reporting ‘old invoices’ on the e-invoice (IRP) portal for taxpayers having aggregate annual turnover (AATO) greater than or equal to INR 100 crores.
In this regard, taxpayers having AATO equal to or greater than INR 100 crores, shall be
mandatorily required to generate e-invoice within 7 days from the date of
invoice. In other words, invoice/s older than 7 days (from document date) cannot
be reported on the e-invoice portal for the purpose of generating IRN.
The said restriction is proposed to be implemented from 1 May
2023.
Non applicability of the above time limit/ restriction
The said time
limit/ restriction shall not apply to:
Taxpayers
having AATO less than INR 100 crores; and
Generation of e-invoice for debit notes/ credit notes
EY Comments
As a background, it may be recalled that while the modalities for
implementing e-invoicing were being formulated, certain validations were
envisaged to restrict generation of e-invoice for dates other than current date
and previous day. However, those validations were removed before the date
of implementation of e-invoicing.
The move to impose time limit for generation of e-invoice seems to be
aiming at ensuring timely compliance, resolving mis-match errors, and
discouraging the cases of issuing back dated invoices.
Considering
the timelines, concerned businesses are recommended to revamp their IT systems
to ensure compliance with the above norms, including aligning the internal
teams to ensure compliance within stipulated timelines.
Further, for the past periods (where e-invoices have not been
generated), it is suggested to track such cases and regularise e-invoice
non-compliances (if any) before 1 May 2023 to avoid any adverse penal
consequences.
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