Tax Query: How will recipient receive e-invoice from suppliers?

In e-invoicing, how will the recipient receive the e-invoice from the suppliers?

The e-invoice system suggests that the supplier sends the JSON file received from the Invoice Registration Portal (IRP) to the recipient, which includes the QR code. Alternatively, the PDF/printed copy of the e-invoice can also be emailed or sent by post to the recipient, for use by the recipient in future business transactions. 

The IRP may soon release a mechanism to enable the system-to-system exchange of e-invoices through ecosystem partners. The same may be provided in due course, but is currently not available.

Does the IRP e-mail the e-invoice to the recipient of supplies?

No, the IRP does not email the e-invoice. Once the supplier receives the signed e-invoice from the IRP, the responsibility is on the supplier to share the e-invoice to his customers. 

Is the supplier’s signature or digital signature required on an e-invoice, while issuing a copy to the recipient?

The provisions of Rule 46 of the Central Goods and Services (CGST) Rules, 2017 apply here. According to Rule 46, the signature/digital signature of the supplier or his authorised representative is required while issuing invoices. However, a proviso to Rule 46 states that the signature/digital signature shall not be required in the case of issuance of an electronic invoice that is in accordance with the provisions of the Information Technology Act, 2000.

Hence, it has been interpreted that in the case of e-invoices, a supplier will not be required to sign/digitally sign the document.

For businesses to whom e-invoicing applies, is carrying a print out of the e-invoice while transporting goods mandatory?

No, a print out is not mandatory to be carried, as long as the e-invoice containing the IRN and QR code, can be electronically produced before the tax officer, for verification. These provisions are governed by Rule 138A(2) of CGST Rules.

Can a supplier add more than one QR code on an e-invoice?

Yes, the supplier is free to add more QR codes to the e-invoice depending on his business needs or statutory requirements, apart from the QR code issued by the IRP. The QR codes need to be marked clearly in such cases to be easily distinguished.

For any clarifications/feedback on the topic, please contact the writer at athena.rebello@cleartax.in