The Goods and Services Tax Network (GSTN) issued an advisory on 4th April, 2019 inviting all taxpayers to Rule 46(b) of the CGST Rules, 2017.
This rule states that the tax invoice issued by a registered person should be inclusive of a consecutive serial number with a maximum of 16 digits. It may be issued in single or multiple series made of numbers, letters, or special characters. The special characters may include a hyphen/dash (-) and a forward slash (/) in any combination unique to the respective financial year.
The Rule 46 of the CGST Rules, 2017 clearly implies that from the beginning of the next Financial Year, i.e. 2019 to 2020 (April 1st, 2019), GST taxpayers are required to start a new invoice series which will be unique to the aforementioned financial year.
Similar to Rule 46, the Rule 49 of the CGST Act, 2017 also puts forward a provision with regard to the issuance of the ‘Bill of Supply’ by a registered taxpayer who has availed the Composition Scheme or who is supplying goods and/or services exempted from tax under GST.
In case the provisions put forward in the Rule 46 and the Rule 49 of the CGST Act, 2017 are not followed by taxpayers, it will be considered as an issue of compliance. Apart from being an issue of compliance, the taxpayers could face separate issues upon generation of E-way bills on the e-way bill portal. Taxpayers may also face issues while filing their returns in form GSTR-1 or while making an application for a refund on the GST portal.
Invoice series can most commonly be sequential, chronological, based on project number, or customer number. To consider an example, if an invoice is generated on 10th April 2019 for a customer number 1234, project number PROJ5678, invoice number 1000, and sequence number 01, a few formats for its invoice series can be:
Therefore, it becomes necessary that taxpayers make the suitable and required modifications in their invoices and bills of supply. Complying with the new GST notifications will help taxpayers in avoiding any sort of inconvenience or penalty for being non-compliant under GST.