Basics on Invoicing under GST Regime

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Complying with the laws related to taxes includes compliance with maintaining accounts books, invoices, records etc. Every business must be aware of invoicing, rules related thereto and know these in detail. We have provided an overview, assessing the process of invoicing under GST as against the traditional indirect tax regime.

Current indirect tax regime –

Under the indirect tax regime, there are two kinds of invoices that are issued, namely, the tax invoice and the retail or commercial invoice. We have provided a brief of the two as follows –

Tax Invoice

  • Issued to registered dealers;
  • May be used for claiming input tax credit;
  • May be in the form of an Excise invoice under Rule 11 of the Central Excise Rules, 2002 or as a Tax Invoice;
  • Details such as buyer’s details (personal and order related), description of goods, excise and VAT levied on the goods etc. are required to be furnished for an Excise Invoice;
  • Details such as buyer’s details (personal and order related), description of the goods, VAT levied on the goods are required to be furnished for the tax invoice.

Retail / Commercial Invoice

  • Issued to an unregistered dealer or a retail customer;
  • May not be used for claiming any input tax credit;
  • Details such as buyer’s details (personal and order related), delivery note related details, description of the goods, VAT levied on the goods are required to be furnished for the tax invoice.

GST regime –

Under the GST regime, there are two kinds of invoices that are issued, namely,the tax invoice and the bill of supply.We have provided a brief of the two as follows –

Tax Invoice

  • Issued to a registered taxable person who supplies any goods or services;
  • Details such as receiver’s and consignee’s details, state code in case the supply is interstate or if the value of taxable supply exceeds INR 50,000, a unique serial number based on the financial year, taxable value of the good after subtracting any discount or abatement, HSNor accounting code.

Bill of Supply

  • Issued upon the supply of goods or services that are exempted;
  • Issued when the supplier pays tax under the composite levy scheme;
  • Details such as receiver’s details only if the receiver is registered, a unique serial number based on the financial year, taxable value of the good after subtracting any discount or abatement, unique ID if issued to a UN body;
  • This bill of supply is not required to be issued when the total value of the goods or services does not exceed INR 100, unless the bill has been requested to be generated;
  • A consolidated bill of supply is required to be generated at the end of every business day for any supplies for which such a bill has not been individually generated.

We have further clarified some queries on issues pertaining to the tax invoice such as –

Time limit for issuance of tax invoice when the supply involves movement of goods

The tax invoice is required to be issued either before the removal of the goods or at the time of the removal of the goods. For example, if F&M Clothing, a garment manufacturer, supplies garment bundles to another dealer Lara Fashion, then the invoice must be issued when these garment bundles are being removed from the transportation van at the premises of Lara Fashion.

Time limit for issuance of tax invoice when the supply does not involve movement of goods

The tax invoice is required to be issued at the time of providing the supply of goods. For example, Lara Fashion purchases mannequins from F&M Clothing which will be assembled at the premises of Lara Fashion by F&M Clothing itself, then the supply does not require any movement of the mannequins / goods and thus the invoice is to be issued when the mannequins are being made available to Lara Fashion.

Time limit for issuance of tax invoice when services are supplied

The tax invoice is required to be issued within 30 days from the date on which the supply of the service has been provided. However, in case the supply is being provided by a bank or any financial institution, then the time limit is extended to 45 days.

Reverse Charge basis

A tax invoice is required to be issued on the date of receipt of the goods or services in the case of a person paying tax on reverse charge basis receives goods or services from an unregistered supplier.

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Number of copies required to be maintained for supply of goods –

It is pertinent to note that three copies of the tax invoices are required to be issued in case of supply of goods, namely, the original copy which is issue to the receiver marked as an original copy meant only for the recipient, a duplicate copy issued to the transporter transporting the goods and marked as a duplicate copy and a triplicate copy for the record of the supplier, marked as a triplicate copy.

In case of a duplicate copy, the physical copy of the invoice is only required if the supplier has not obtained an invoice reference number as explained in our earlier articles. The invoice reference number is provided by the GST portal when a supplier of a good uploads the tax invoice against a consignment and the validity period of the same is 30 days from the date of uploading the invoice.

Number of copies required to be maintained for supply of services –

It is vital to note that in the case of supply of services, only two copies of the invoices are required to be maintained, namely, the original invoice to be given to the receiver of the goods, marked as an original copy meant for the recipient and a duplicate copy to be retained by the supplier marked as a duplicate copy.

Details in a tax invoice meant for export purposes –

A tax invoice that is required for export reasons contains several details such as the following –

  • Personal details of the recipient including the name and address
  • Header stating “supply meant for export on payment of IGST” or the words “supply meant for export under bond without payment of IGST”
  • Address for delivery of the supply
  • Number and date on which form ARE-1 or application for removal of the goods meant for export was issued

Revising values of invoices already generated –

For the purpose of revising a value or an amount on an invoice that has already been generated, taxable persons / suppliers may use a debit or a credit note to be issued to the recipient. We have provided a brief overview of the two as follows –

Debit Note / Supplementary Invoice

  • Issued by the supplier;
  • Issued for recording GST charged on the goods or an increase in the taxable value of the goods in the original invoice.

Credit Note

  • Issued by a supplier;
  • Issued for recording GST charged on the goods or any decrease in the taxable value of the goods in the original invoice.
  • Required to be issued on or prior to September 30th after the end of a financial year in which the supply in question was made; additionally, may be filed along with filing of the annual return (whichever falls earlier).

As an illustration, let us take F&M Clothing that sells garment bundles amounting to INR 60,000 to Lara Fashion, a registered dealer, on November 3, 2017. On November 4, 2017 garment bundles amounting to INR 10,000 were returned on account of defects by Lara Fashion to F&M Clothing. F&M Clothing thus decided to issue a credit note on this basis.

We are required to take into account the last date on which F&M Clothing is required to issue the credit note using the following logic (taking into account whichever date is earlier) –

  • Either F&M Clothing files an annual return for the financial year 2017-18 on December 1, 2018 in which case the condition for ascertaining the last date of the credit note will be September 30 following the end of the financial year in which the supply was made; or
  • F&M Clothing files an annual return for the financial year 2017-18 on May 31, 2018 in which case the condition for ascertaining the last date of the credit note will be May 31, 2018 following the date of filing the annual return.

Details in a debit note / supplementary invoice or acredit note –

A debit note / supplementary invoice or a credit note contains several details such as the following –

  • Header to read ‘revised invoice’ or ‘supplementary invoice’ to indicate that it is a revised copy differentiated from the original invoice.
  • Personal details of the supplier such as the name, address and GSTIN.
  • Serial number unique to a financial year.
  • Date when the document was issued.
  • Personal details in case of a registered recipient, such as the name, address, GSTIN, unique ID number; alternatively, personal details in case of an unregistered recipient such as name, address, delivery address, state name and state code.
  • Date of the original tax invoice issued and the serial number of the same.
  • Total taxable value of the goods / services along with the total rate and amount of tax that has been either credited or debited to the recipient.
  • Signature of the supplier (maybe physical or digital); alternatively, signature of an authorized representative on behalf of the supplier in case the supplier is not available.

 

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