Tax Query: Once the details of an e-invoice have been modified on the GST portal, will the e-invoice be valid?

1. Can I amend the details of an invoice for which an IRN has already been generated? 

Ans: Amending the details of an e-invoice is not possible once an invoice reference number (IRN) has been generated on the Invoice Registration Portal (IRP). Any changes in the invoice details reported to the IRP can be carried out on the GST portal before filing the GSTR-1. However, the NIC has stated that these changes made will be flagged and intimated to the proper officer.

2. Post the modification of e-invoice data on the GST portal, will the e-Invoice be valid? Why does the source ‘e-invoice’ get deleted post modification?

Ans: The validity of an e-invoice will not get affected if the e-invoice data were to get modified in the GSTR-1. However, the government has issued an advisory wherein it states that taxpayers are advised to modify or update only those documents where the details auto-populated from the e-invoices are not as per the actual e-invoice issued. In such cases, the ‘Source’, ‘IRN’ and ‘IRN date’ fields will be reset to blank in the respective tables of the GSTR-1. These edited documents will be treated as if they were not auto-populated but uploaded separately by the taxpayer. 

Taxpayers editing e-invoice data in the GSTR-1 will need to reconcile all the modifications and be ready with the data as the department might issue a notice stating that there are differences between the e-invoices and GSTR-1 at any point in time.

3. Who is responsible for generating e-invoices in the case of Reverse Charge Mechanism (RCM) transactions? 

Ans: RCM-related invoices will need to be generated by the supplier and not by the recipient. In the case of RCM invoices issued for B2B and SEZ transactions, the supplier will be required to generate the IRN and will need to do so with the RCM flag set to ‘Y’ on the e-invoice. In the case of B2C RCM invoices or self invoices, no IRN will need to be generated.

4. When an IRN is cancelled, will the associated e-way bill also get automatically cancelled? 

Ans: As per protocol, an e-way bill linked to an e-invoice will have to be cancelled first. Only then can the IRN be cancelled. It is to be noted that an e-way bill cannot be cancelled if it has already been verified by an officer, and hence, even the IRN cannot be cancelled in such cases.

5. If I have committed a mistake in an invoice and generated an IRN for it, can I cancel and re-generate an IRN again for the same invoice? 

Ans: A document number cannot be reused even after the cancellation of an IRN. The original invoice will also have to be cancelled, and a new invoice with a new invoice number will need to be generated. Post which, an IRN can be generated for the same.

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