Dynamic Quick Response (QR) Code on B2C invoices and compliance under GST was notified by the Ministry of Finance vide Notification No.14/2020 – Central Tax dated 21st March 2020.
Those taxpayers having an aggregate turnover of more than Rs. 500 crores were required dynamic QR codes on their B2C invoices (registered person to an unregistered customer) issued by them with effect from 1st December 2020.
In continuation of the said notification, another Notification no. 89/2020 – Central Tax was issued on 29th November 2020 whereby it was notified that the penalty will be waived off for non-compliance of the said provisions i.e., laid down under Notification No. 14/2020 for the period from 1st December 2020 to 31st March 2021, subject to the condition that the said taxpayer complies the notified provisions from 1st April 2021 onwards.
Relaxation of penalty waiver depends upon the compliances done by the said taxpayer from 1st April 2021 onwards. If the provisions of the said notification do not comply after 1st April 2021, in that case, provision of penalty will be levied on the said taxpayer.
Board has exercised its power conferred u/s 168(1) of the CGST Act, 2017 and issued some clarification regarding the applicability of the Dynamic Quick Response (QR) Code on B2C invoices and compliance under GST vide Circular No. 146/02/2021 – GST
Issue 1: Which invoices are covered/ applicable under Notification No. 14/2020 – Central Tax dated 21st March 2020?
Clarification: The said notification is applicable to the Tax Invoices that are issued by those registered persons to the unregistered person i.e., B2C Invoices, whose AGT (annual aggregate turnover) exceeds Rs. 500 crores in any of the financial year from 2017-18 onwards.
Issue 2: In what cases the said notification is not applicable?
Clarification: The said notification is not applicable to B2C Invoices that are issued in the below mentioned cases:
- Where the supplier of taxable service is any of the following:
|An insurer or a banking company or any financial institution including NBFC’s.|
|GTA supplying any services in relation to transportation of goods by road through a goods carriage.|
|Supplying passenger transportation service|
|Supplying the services by way of admission to an exhibition of the cinematograph in films on multiple screens|
- A registered person registered u/s 14 of the IGST Act 2017, made OIDAR supplies to an unregistered person.
Issue 3: Would this requirement be applicable on invoices issued for supplies made for exports?
Clarification: As far as export invoices are concerned e-invoices of the same is required vide Notification No.13/2020 – Central Tax dated 21st March 2020 thereby treating them as B2B Invoices i.e., Business to Business supplies and the above said Notification No.14/2020- Central Tax dated 21st March 2020 will not be applicable in that scenario.
Issue 4: What are the details that are required to be captured in the QR Code?
Clarification: QR code should contain the following details:
|Supplier UPI ID|
|Payee’s Bank Account number and IFSC|
|Invoice Number and Invoice date|
|Total Invoice Value|
|Segregated GST component i.e., IGST, CGST, SGST, CESS, etc.|
|Note: It should be able to scanned to make a digital payment.|
Issue 5: What if the supplier provides the QR code, but the customer opts to make the payment without the use of a QR Code, in that situation will it be considered as compliance with the Dynamic QR Code on the invoice?
Clarification: Yes, it will be taking into consideration and it shall be deemed to have complied with the requirement of having a Dynamic QR Code.
|If the customer pays for the invoice using any mode like UPI, Credit card/ debit card, online banking, cash, or any combination of the various modes of payment, with or without using the Dynamic QR code, |
The Supplier should have provided a cross-reference of such payment by providing details such as transaction ID, Date of making payment, time of payment and the amount, mode of payment, etc. against such invoice; or
|Customer pays in cash without using Dynamic QR code, |
The Supplier provides a cross-reference of the amount paid in cash along with the date of such payment against the said invoice.
Issue 6: How it will be taken into account if the supplier receives the payment via an electronic mode of payment like UPI Collect, UPI Intent, or any similar other modes of payment either through mobile-based applications or computer-based applications where Dynamic Code QR code is not displayed, but the details of the merchant as well as the transaction are displayed or captured?
Clarification: In such cases, where the cross-reference of the payment is made available on the said invoice, it shall be deemed to comply with the requirement of the Dynamic QR Code.
Note: If the payment is made after the issuance of the invoice, the supplier shall provide a Dynamic QR Code on the invoice.
Issue 7: For pre-paid invoices, it is mandatory to generate or print Dynamic QR code on B2C invoices?
Clarification: If the cross-reference of the payment received is made available on the invoice, it would be deemed to have complied with the requirement of the Dynamic QR code.
Issue 8: If the ECO or online application has complied with the Dynamic QR code requirements, will the suppliers using such an e-commerce portal still be required to comply with the requirement of the Dynamic QR code?
Clarification: The provisions notified shall apply to each registered person separately if such person is liable to issue invoices with Dynamic QR code as per the said notification.
In the case of pre-paid invoices and post-invoice payments, the conditions mentioned above are the same.
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