GST B2C QR Code, Applicability of Dynamic QR Code on GST B2C invoices
Central Board of Indirect Taxes and Customs (CBIC)
Notification No. 14/2020-Central Tax, dated 21st March 2020 requires Dynamic QR Code on GST B2C invoices issued by taxpayers having aggregate turnover 500 crore rupees and above, w.e.f. 01.12.2020. Further, vide Notification No. 89/2020- Central Tax, dated 29th November 2020, penalty has been waived for non-compliance of the provisions of Notification No.14/2020 – Central Tax for the period from 01st December, 2020 to 31st March, 2021, subject to the condition that the said person complies with the provisions of the said Notification from 01st April, 2021.
As there were no detailed instructions in the said notification about the information to be encoded in the GST B2C QR Codes and many references were raised by trade and industry seeking clarification on applicability of Dynamic Quick Response (QR) Code on GST B2C (Registered person to Customer) invoices and compliance of Notification No. 14/2020-Central Tax, dated 21st March, 2020 as amended. The issues were examined by CBIC and calrification was issued vide Circular no. 146/02/2021-GST dated 23rd February, 2021. The issues raised by the trade and industry and clarification issued by CBIC, has been detailed below:
i. Where the supplier of taxable service is:
a) an insurer or a banking company or a financial institution, including a non-banking financial company;
b) a goods transport agency supplying services in relation to transportation of goods by road in a goods carriage;
c) supplying passenger transportation service;
d) supplying services by way of admission to exhibition of cinematograph in films in multiplex screens
ii. OIDAR supplies made by any registered person, who has obtained registration under section 14 of the IGST Act 2017, to an unregistered person.
As regards the supplies made for exports, though such supplies are made by a registered person to an unregistered person, however, as e-invoices are required to be issued in respect of supplies for exports, in terms of Notification no. 13/2020-Central Tax, dated 21st March, 2020 treating them as Business to Business (B2B) supplies, Notification no. 14/2020- Central Tax, dated 21st March, 2020 will not be applicable to them.
i. Supplier GSTIN number
ii. Supplier UPI ID
iii. Payee’s Bank A/C number and IFSC
iv. Invoice number & invoice date,
v. Total Invoice Value and
vi. GST amount along with breakup i.e. CGST, SGST, IGST, CESS, etc.
Further, Dynamic QR Code should be such that it can be scanned to make a digital payment.
In cases where the supplier, has digitally displayed the Dynamic QR Code and the customer pays for the invoice: -
i. Using any mode like UPI, credit/ debit card or online banking or cash or combination of various modes of payment, with or without using Dynamic QR Code, and the supplier provides a cross reference of the payment (transaction id along with date, time and amount of payment, mode of payment like UPI, Credit card, Debit card, online banking etc.) on the invoice ; or
ii. In cash, without using Dynamic QR Code and the supplier provides a cross reference of the amount paid in cash , along with date of such payment on the invoice;
The said invoice shall be deemed to have complied with the requirement of having Dynamic QR Code.
So it is now clear, if the payment is made before issuing of GST B2C invoices, then the suppliers having turnover Rs. 500 crore and is not in exempted category, can give cross referance of the payment in the GST B2C invoices without printing the dynamic QR Code on GST B2C Invoices otherwise, the supplier has to print dynamic QR Code on GST B2C invoices.
For ecommerce Operators, if the payment is received online, before issuing the invoice and cross reference of the payment is made on the invoice, then dynamic B2C Qr Code is not required, but if the payment is made on the delivery of the items, then such invoices should have dynamic B2C QR Code.
As there were no detailed instructions in the said notification about the information to be encoded in the GST B2C QR Codes and many references were raised by trade and industry seeking clarification on applicability of Dynamic Quick Response (QR) Code on GST B2C (Registered person to Customer) invoices and compliance of Notification No. 14/2020-Central Tax, dated 21st March, 2020 as amended. The issues were examined by CBIC and calrification was issued vide Circular no. 146/02/2021-GST dated 23rd February, 2021. The issues raised by the trade and industry and clarification issued by CBIC, has been detailed below:
Types of Invoices Notification No 14/2020- Central Tax applicable? Whether Notification applicable on Export Suppies?
Vide Circular No. 146/02/2021-GST, CBIC clarified that following entities are exempted from issuing B2C QR Code Invoices:i. Where the supplier of taxable service is:
a) an insurer or a banking company or a financial institution, including a non-banking financial company;
b) a goods transport agency supplying services in relation to transportation of goods by road in a goods carriage;
c) supplying passenger transportation service;
d) supplying services by way of admission to exhibition of cinematograph in films in multiplex screens
ii. OIDAR supplies made by any registered person, who has obtained registration under section 14 of the IGST Act 2017, to an unregistered person.
As regards the supplies made for exports, though such supplies are made by a registered person to an unregistered person, however, as e-invoices are required to be issued in respect of supplies for exports, in terms of Notification no. 13/2020-Central Tax, dated 21st March, 2020 treating them as Business to Business (B2B) supplies, Notification no. 14/2020- Central Tax, dated 21st March, 2020 will not be applicable to them.
GST B2C QR Code Parameters
CBIC further calrified vide Circular No. 146/02/2021-GST that Dynamic QR Code, in terms of Notification No. 14/2020-Central Tax, dated 21st March, 2020 is required, inter-alia, to contain the following information: -i. Supplier GSTIN number
ii. Supplier UPI ID
iii. Payee’s Bank A/C number and IFSC
iv. Invoice number & invoice date,
v. Total Invoice Value and
vi. GST amount along with breakup i.e. CGST, SGST, IGST, CESS, etc.
Further, Dynamic QR Code should be such that it can be scanned to make a digital payment.
If supplier provides/ displays Dynamic QR Code, but the customer opts to make payment without using Dynamic QR Code
CBIC also clarified vide the said circular that If the supplier has issued invoice having Dynamic QR Code for payment, the said invoice shall be deemed to have complied with Dynamic QR Code requirements.In cases where the supplier, has digitally displayed the Dynamic QR Code and the customer pays for the invoice: -
i. Using any mode like UPI, credit/ debit card or online banking or cash or combination of various modes of payment, with or without using Dynamic QR Code, and the supplier provides a cross reference of the payment (transaction id along with date, time and amount of payment, mode of payment like UPI, Credit card, Debit card, online banking etc.) on the invoice ; or
ii. In cash, without using Dynamic QR Code and the supplier provides a cross reference of the amount paid in cash , along with date of such payment on the invoice;
The said invoice shall be deemed to have complied with the requirement of having Dynamic QR Code.
If the supplier makes available to customers an electronic mode of payment like UPI Collect, UPI Intent or similar other modes of payment, through mobile applications or computer based applications, where though Dynamic QR Code is not displayed, but the details of merchant as well as transaction are displayed/ captured otherwise, how can the requirement of Dynamic QR Code as per this notification be complied with?
If the supplier makes available to customers an electronic mode of payment like UPI Collect, UPI Intent or similar other modes of payment, through mobile applications or computer based applications, where though Dynamic QR Code is not displayed, but the details of merchant as well as transaction are displayed/ captured otherwise, in such cases, if the cross reference of the payment made using such electronic modes of payment is made on the invoice, the invoice shall be deemed to comply with the requirement of Dynamic QR Code.Is generation/ printing of Dynamic QR Code on B2C invoices mandatory for pre-paid invoices i.e. where payment has been made before issuance of the invoice?
If cross reference of the payment received either through electronic mode or through cash or combination thereof is made on the invoice, then the invoice would be deemed to have complied with the requirement of Dynamic QR Code. In cases other than pre-paid supply i.e. where payment is made after generation / issuance of invoice, the supplier shall provide Dynamic QR Code on the invoice.If the E-commerce operator (ECO) or the online application has complied with the Dynamic QR Code requirements, will the suppliers using such e-commerce portal or application for supplies still be required to comply with the requirement of Dynamic QR Code?
The provisions of the notification shall apply to each supplier/registered person separately, if such person is liable to issue invoices with Dynamic QR Code for B2C supplies as per the said notification. In case, the supplier is making supply through the E- commerce portal or application, and the said supplier gives cross references of the payment received in respect of the said supply on the invoice, then such invoices would be deemed to have complied with the requirements of Dynamic QR Code. In cases other than pre-paid supply i.e. where payment is made after generation / issuance of invoice, the supplier shall provide Dynamic QR Code on the invoice.So it is now clear, if the payment is made before issuing of GST B2C invoices, then the suppliers having turnover Rs. 500 crore and is not in exempted category, can give cross referance of the payment in the GST B2C invoices without printing the dynamic QR Code on GST B2C Invoices otherwise, the supplier has to print dynamic QR Code on GST B2C invoices.
For ecommerce Operators, if the payment is received online, before issuing the invoice and cross reference of the payment is made on the invoice, then dynamic B2C Qr Code is not required, but if the payment is made on the delivery of the items, then such invoices should have dynamic B2C QR Code.