Challenges at various stages of e-invoicing implementation

A) Preparing for Invoice Reference Number (IRN)

I. Updating ERP

Companies will have to upgrade their systems so as to get ready for e-invoicing. If there isn’t a separate team to run the technicalities of the process, it will be quite challenging. The data points needed for generating an IRN are to be taken from the systems and therefore an analysis of data points is required to ensure these are available in the system.

II. Connecting to Invoice Registration Portal (IRP)

Invoice Registration Portal Ivan be accessed by the taxpayers who come under the threshold via APIs which provide the mechanism of receiving and sending the data from the taxpayers. In order get things in order, this requires constant assistance and support from an expert at each level. It is recommended to use an authorized GSP so that the taxpayers can manage the  entire process smoothly.

B) Generating Invoice Reference Number (IRN)

I. Handling errors

E-invoicing is applicable to business to business transactions. Business to business supplies include exports as well as domestic supplies, supplies through E-commerce Operators, RCM are covered under E-Invoicing.

Therefore, the risk of errors is high. It isn’t a smooth ride for many to generate an e-invoice.

II. E-way bill

Generation of E-way Bill is now entwined with E-Invoicing. Not only IRN but also E-way bill can be generated by IRP, for the documents that qualify. Hence, depending on the data sent, the IRP system returns E-way number or IRN or both. IRP communicates with E-Way Bill in real time and generates the W-Way bill, if the taxpayer sends the details of transport along with invoice details.

III. Handling certain business scenarios

There are specific business scenarios where value validations go wrong. For instance, there is TCS on sales for which no different data point is accessible to record the same and hence it needs to be adjusted in other charges fields.

C) Post IRN

I. Cancellation

For cancelling an IRN you just have a 24 hours window. Besides, there is also no editing available in case you make any mistake while generating the IRN. If a mistake is made, the taxpayer needs to cancel the entire IRN and generate an invoice altogether with a new invoice number. If you want to cancel the invoice after 24 hours, you can either do it in the GSTN system or you can do it by issuing a credit note. It is better to issue a credit note because if you delete this from the GST system alone, the invoice will still be active in the IRP system.

II. GSTR 1 Reporting

Government will auto-populate on a T+2 basis. Even so, there are issues that still carry on. Therefore, it is necessary to check self records v/s Government’s populated records. This will also help to determine any cancellation issues and if any amendment is needed.

OTHER E-INVOICING CHALLENGES

Data extraction as per e-invoice standard

It is necessary to note that the validation rules could be different from the way data is currently captured. Say, rounding off, decimal places for quantity, HSN code maintained, etc.

Enabling GSTINs on e-invoice portal

For companies that are under the e-invoicing threshold, the applicability is at PAN level.

All possibilities that GSTINs within PAN will be enabled. However, if not, then a form has to be filled in order to enable it at the NIC portal.