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Tax Alert: E-invoicing and GST return changes

24 July 2020

Goods and Service Tax Network (GSTN) is planning to introduce certain new features/changes to the existing GST returns. The proposed changes may include delinking of original invoice details with credit and debit notes, auto calculation of liability from GSTR 1 into GSTR 3B, inclusion of additional features in GSTR-2A/6A, availability of FORM GSTR 2B etc. Further, E- invoicing is proposed to be implemented from 01 October 2020 for taxpayers with turnover  INR 5bn or more.

1. Changes/added features in the existing GST return filing system:

While the new GST return system is proposed to be implemented effective 01 October 2020, GSTN has now planned to improve the existing GST return filing system with more features/changes, as required to make the taxpayers’ compliance easier. The following are the proposed changes/features:

S. No.

Changes in API



Credit/debit note delinking and amendments to credit/debit note

Refer Table CDN, CDNA, CDNUR, CDNURA, small change in B2CL in FORMS GSTR 1, GSTR 6

Delinking of original invoice details with credit and debit notes as well as amendments to credit/debit notes. Therefore, taxpayers shall not be required to report the original invoice number and date while filing GSTR 1 and GSTR 6.

B2CL shall be merged with B2CS and there will be only one category for reporting the business-to-customer transactions.


CDN delinking related changes in FORMS GSTR 2A, GSTR 4A and GSTR 6A

As stated above, details of the original invoice shall get delinked with the credit and debit notes, accordingly similar changes shall be adopted in FORM GSTR 2A and FORM GSTR 6A as well.


Inclusion of GSTR 1 filing date, GSTR 3B filing status, GSTR 1 period, invoice amendment flag, type of change etc. in FORM GSTR 2A

In FORM GSTR 2A the following details shall be made available to the taxpayers:

  • Date of filing GSTR 1 by the vendor
  • Status of filing GSTR 3B of the vendor
  • Period of which a particular invoice pertains to
  • Identification flag whether an invoice has been amended or not and
  • If amended, nature of the change


Auto calculation of liability from- FORM GSTR 1 in to GSTR 3B

Based on the data uploaded and filed in FORM GSTR 1, the liability shall be auto populated in FORM GSTR 3B.


GSTR 2A - IMPG and IMPEG details

The details of import of goods and purchases made from an SEZ unit, shall also be auto populated in FORM GSTR 2A


Details of Table 8A of GSTR 9

Table 8A of GSTR 9 is an auto population of ITC as per GSTR 2A. Invoice wise details of Table 8A of FORM GSTR 9 shall be made available to taxpayers.


FORM GSTR 2B shall be made available to taxpayers

Based on the information provided by the GSTN officials through a webinar recently, we are given to understand that a new FORM GSTR 2B shall be made available to the taxpayer, which shall have the following specifications:

  • A static statement which can be generated on a monthly basis
  • Will have document level data of ITC available and ITC not available
  • Filter and search functionality shall be provided and
  • Option to download the form in PDF and excel shall be provided


GSTN has provided various indicative dates for the release of the above-mentioned changes. We shall keep you posted as and when the same is made operational.  

2. E-invoicing under GST Law

Presently, transactions between buyer and seller are not authenticated by the government.

Under the new system, business transactions will be authenticated electronically by the portals maintained by the government. The system would enable complete trail of B2B transactions, eliminate fake invoices, control over fictitious ITC claims, real time data access by tax authorities and ultimately, the reduction of tax evasion significantly.

“E-invoicing or Electronic-Invoicing” for specified categories of taxpayers whose aggregate turnover exceeds INR 01bn was earlier planned to be implemented effective 01 October 2020.     

Based on the recent media reports and discussions at various forums, it appears that the government may go ahead with the implementation of e-invoicing in a phased manner from 01 October 2020 and we understand the following may be formally notified in few days:

  • Phase-1 of e-invoicing which shall be mandatory for companies having a turnover of INR 5bn or more (as against 01bn earlier); and
  • A new version of API is expected soon.

Further, on the following points, clarity is awaited from the government:

  • Printing of QR code for B2B invoices.
  • Removal of business validations available in the IRP which are not in accordance with the GST law.

BDO Comments

With the reasonable visibility of the government’s plan to continue with the existing GST return filing system, except for few additional features/ changes and the proposed implementation of e-invoicing for the applicable taxpayers, every business is required to ensure preparedness and to have the checks and balances on their IT systems, documentations, procedures, processes. It is also important to invite the attention of various stakeholders from marketing/sales, logistics, finance, tax and IT systems through the entire business process, in order to be compliant on the effective roll-out.