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Here are answers to most frequently asked questions.

FAQ's

What are some of the key challenges?

Quality of data, addressing errors and reconciliation of returns, synchronization with Goods and Services Tax Network (GSTN) and timely and appropriate credits for managing impact on working capital.

What is the impact of GST compliance on businesses?

GST Compliance is top of the agenda for companies big or small. Change from onetime filing to continuous/monthly filing of taxes with government, it requires high degree of accuracy and more efforts. Complete shift with respect to filing of taxes from traditional paper and offline filing to online and digital form of filing. Maintaining non-core system / applications for filing taxes.

Who are GSPs and how will they help in effective compliance of GST?

The GST Suvidha Providers or GSPs are licensed and authorized by the Goods and Services Tax Network (GSTN) of the Government to connect to the GSTN using the published APIs GSP’s will facilitate taxpayers in uploading securely GST returns in a prescribed format GSPs can customize products that address the compliance needs of different segment of users

Who are ASPs and what will be their role?

ASPs are Application Service Providers ASP functionality will be to prepare monthly and annual GST returns basis taxpayer data, enable reconciliation of returns for appropriate and timely credits ASP will file returns for taxpayers through authorized GSPs

What is the objective of using a GSP-ASP?

Primary objective of ASP-GSP is to ensure compliance and governance under the GST regime, which will require deep domain and technology knowledge. ASPs’ drive long term service subscription model to provide the tax filing and managing the reconciliation process. Organizations must recognize the value of the service of ASP as data sharing must comply to maintaining privacy, reliability and control.

What is the scope of ‘supply’ under the GST law?

The term ‘supply’ is wide in its import covers all forms of supply of goods or services or both that includes sale, transfer, barter, exchange, license, rental, lease or disposal made or agreed to be made for a consideration by a person in the course or furtherance of business. It also includes import of service. The model GST law also provides for including certain transactions made without consideration within the scope of supply.

Different companies have different types of accounting software packages and no specific format are mandated for keeping records. How will department be able to read into these complex software?

As per Section 153 of the CGST/SGST Act, having regard to the nature and complexity of a case and in the interest of revenue, department may take assistance from an expert at any state of scrutiny, inquiry, investigation or any other proceedings

Is there any provision in GST for tax treatment of goods returned by the recipient?

Yes, Section 34 deals with such situations. Where the goods supplied are returned by the recipient, the registered person (supplier of goods) may issue to the recipient a credit note containing the prescribed particulars. The details of the credit note shall be declared by the supplier in the returns for the month during which such credit note was issued but not later than September following the end of the year in which such supply was made or the date of filing of the relevant annual return, whichever is earlier. The details of the credit note shall be matched with the corresponding reduction in claim for input tax credit by the recipient in his valid return for the same tax period or any subsequent tax period and the claim for reduction in output tax liability by the supplier that matches with the corresponding reduction in claim for ITC by the recipient shall be finally accepted and communicated to both parties.

What is meant by Reverse Charge?

It means the liability to pay tax is on the recipient of supply of goods and services instead of the supplier of such goods or services in respect of notified categories of supply.

Is the reverse charge mechanism applicable only to services?

No, reverse charge applies to supplies of both goods and services, as notified by the Government on the recommendations of the GST Council.

What will be the implications in case of receipt of supply from unregistered persons?

In case of receipt of supply from an unregistered person, the registered person who is receiving goods or services shall be liable to pay tax under reverse charge mechanism.

What will be the effective date of registration?

Where the application for registration has been submitted within thirty days from the date on which the person becomes liable to registration, the effective date of registration shall be the date on which he became liable for registration. Where an application for registration has been submitted by the applicant after thirty days from the date of his becoming liable to registration, the effective date of registration shall be the date of grant of registration. In case of a person taking registration voluntarily while being within the threshold exemption limit for paying tax, the effective date of registration shall be the date of order of registration.

What is the purpose of Compliance rating mechanism?

Where the application for registration has been submitted within thirty days from the date on which the person becomes liable to registration, the effective date of registration shall be the date on which he became liable for registration. Where an application for registration has been submitted by the applicant after thirty days from the date of his becoming liable to registration, the effective date of registration shall be the date of grant of registration. In case of a person taking registration voluntarily while being within the threshold exemption limit for paying tax, the effective date of registration shall be the date of order of registration.

Is there any facility for digital signature in the GSTN registration?

Tax payers would have the option to sign the submitted application using valid digital signatures. There will be two options for electronically signing the application or other submissions- by e-signing through Aadhar number, or through DSC i.e. by registering the tax payer’s digital signature certificate with GST portal. However, companies or limited liability partnership entities will have to sign mandatorily through DSC only. Only level 2 and level 3 DSC certificates will be acceptable for signature purpose

Import of Goods is conspicuous by its absence in Section 7. Why?

Import of goods is dealt separately under the Customs Act, 1962, wherein IGST shall be levied as additional duty of customs in addition to basic customs duty under the Customs Tariff Act, 1975.

Are self-supplies taxable under GST?

Inter-state self-supplies such as stock transfers, branch transfers or consignment sales shall be taxable under IGST even though such transactions may not involve payment of consideration. Every supplier is liable to register under the GST law in the State or Union territory from where he makes a taxable supply of goods or services or both in terms of Section 22 of the model GST law. However, intra-state self-supplies are not taxable subject to not opting for registration as business vertical.

What are inter-state supplies and intra-state supplies?

Inter-state and intra-state supplies have specifically been defined in Section 7(1), 7(2) and 8(1), 8(2) of the IGST Act respectively. Broadly, where the location of the supplier and the place of supply are in same state it will be intra-state and where it is in different states it will be inter-state supplies.

How will tax liability on a mixed supply be determined under GST?

A mixed supply comprising two or more supplies shall be treated as supply of that particular supply which attracts the highest rate of tax.

What is meant by zero rated supply under GST?

Zero rated supply means export of goods and/or services or supply of goods and/or services to a SEZ developer or a SEZ Unit.

Will import of services without consideration be taxable under GST?

As a general principle, import of services without consideration will not be considered as supply under GST in terms of Section 7. However, import of services by a taxable person from a related person or from any of his other establishments outside India, in the course or furtherance of business, even without consideration will be treated as supply in terms of Sl. No.4 of Schedule I.

What is the linkage between GSTN and the authorized Banks?

There will be real time two-way linkage between the GSTN and the Core Banking Solution (CBS) of the Bank. CPIN is automatically routed to the Bank via electronic string for verification and receiving payment and a challan identification number (CIN) is automatically sent by the Bank to the Common Portal confirming payment receipt. No manual intervention will be involved in the process by any one including bank cashier or teller or the tax payer.

What are the main features of GST payment process?

The payment processes under GST Act(s) have the following features: • Electronically generated challan from GSTN Common Portal in all modes of payment and no use of manually prepared challan; • Facilitation for the tax payer by providing hassle free, anytime, anywhere mode of payment of tax; • Convenience of making payment online; • Logical tax collection data in electronic format; • Faster remittance of tax revenue to the Government Account; • Paperless transactions; • Speedy Accounting and reporting; • Electronic reconciliation of all receipts; • Simplified procedure for banks • Warehousing of Digital Challan.

How can payment be done?

Payment can be done by the following methods: (i) Through debit of Credit Ledger of the tax payer maintained on the Common Portal – ONLY Tax can be paid. Interest, Penalty and Fees cannot be paid by debit in the credit ledger. Tax payers shall be allowed to take credit of taxes paid on inputs (input tax credit) and utilize the same for payment of output tax. However, no input tax credit on account of CGST shall be utilized towards payment of SGST and vice versa. The credit of IGST would be permitted to be utilized for payment of IGST, CGST and SGST in that order. (ii) In cash by debit in the Cash Ledger of the tax payer maintained on the Common Portal. Money can be deposited in the Cash Ledger by different modes, namely, E-Payment (Internet Banking, Credit Card, Debit Card); Real Time Gross Settlement (RTGS)/ National Electronic Fund Transfer (NEFT); Over the Counter Payment in branches of Banks Authorized to accept deposit of GST.

When is payment of taxes to be made by the Supplier?

Payment of taxes by the normal tax payer is to be done on monthly basis by the 20th of the succeeding month. Cash payments will be first deposited in the Cash Ledger and the tax payer shall debit the ledger while making payment in the monthly returns and shall reflect the relevant debit entry number in his return. As mentioned earlier, payment can also be debited from the Credit Ledger. Payment of taxes for the month of March shall be paid by the 20th of April. Composition tax payers will need to pay tax on quarterly basis.

Whether time limit for payment of tax can be extended or paid in monthly installments?

No, this is not permitted in case of self-assessed liability. In other cases, competent authority has been empowered to extend the time period or allow payment in instalments. (Section 80 of the CGST/SGST Act).

Which date is considered as date of deposit of the tax dues – Date of presentation of cheque or Date of payment or Date of credit of amount in the account of government?

It is the date of credit to the Government account.

What is a tax liability register?

Tax Liability Register will reflect the total tax liability of a taxpayer (after netting) for the particular month.

What are E-Ledgers?

Electronic Ledgers or E-Ledgers are statements of cash and input tax credit in respect of each registered taxpayer. In addition, each taxpayer shall also have an electronic tax liability register. Once a taxpayer is registered on Common Portal (GSTN), two e-ledgers (Cash &Input Tax Credit ledger) and an electronic tax liability register will be automatically opened and displayed on his dash board at all times.

What is a Cash Ledger?

The cash ledger will reflect all deposits made in cash, and TDS/TCS made on account of the taxpayer. The information will be reflected on real time basis. This ledger can be used for making any payment on account of GST.

Can a tax payer generate challan in multiple sittings?

Yes, a taxpayer can partially fill in the challan form and temporarily “save” the challan for completion at a later stage. A saved challan can be “edited” before finalization. After the tax payer has finalized the challan, he will generate the challan, for use of payment of taxes. The remitter will have option of printing the challan for his record.

What is an ITC Ledger?

Input Tax Credit as self-assessed in monthly returns will be reflected in the ITC Ledger. The credit in this ledger can be used to make payment of TAX ONLY and not other amounts such as interest, penalty, fees etc.

Can a challan generated online be modified?

No. After logging into GSTN portal for generation of challan, payment particulars have to be fed in by the tax payer or his authorized person. He can save the challan midway for future updation. However once the challan is finalized and CPIN generated, no further changes can be made to it by the taxpayer.

What is the linkage between GSTN and the authorized Banks?

There will be real time two-way linkage between the GSTN and the Core Banking Solution (CBS) of the Bank. CPIN is automatically routed to the Bank via electronic string for verification and receiving payment and a challan identification number (CIN) is automatically sent by the Bank to the Common Portal confirming payment receipt. No manual intervention will be involved in the process by any one including bank cashier or teller or the tax payer.

Is there a validity period of challan?

Yes, a challan will be valid for fifteen days after its generation and thereafter it will be purged from the System. However, the tax payer can generate another challan at his convenience.

What is a CPIN?

CPIN stands for Common Portal Identification Number (CPIN) given at the time of generation of challan. It is a 14-digit unique number to identify the challan. As stated above, the CPIN remains valid for a period of 15 days.

What is a CIN and what is its relevance?

CIN stands for Challan Identification Number. It is a 17-digit number that is 14-digit CPIN plus 3-digit Bank Code. CIN is generated by the authorized banks/ Reserve Bank of India (RBI) when payment is actually received by such authorized banks or RBI and credited in the relevant government account held with them. It is an indication that the payment has been realized and credited to the appropriate government account. CIN is communicated by the authorized bank to taxpayer as well as to GSTN.

What is the sequence of payment of tax where that taxpayer has liabilities for previous months also?

Section 49(8) prescribes an order of payment where the taxpayer has tax liability beyond the current return period. In such a situation, the order of payment to be followed is: First self-assessed tax and other dues for the previous period; thereafter self-assessed tax and other dues for the current period; and thereafter any other amounts payable including any confirmed demands under section 73 or 74. This sequence has to be mandatorily followed.

What does the expression “Other dues” referred to above mean?

The expression “other dues” means interest, penalty, fee or any other amount payable under the Act or the rules made thereunder.

What is an E-FPB?

E-FPB stands for Electronic Focal Point Branch. These are branches of authorized banks which are authorized to collect payment of GST. Each authorized bank will nominate only one branch as its E-FPB for pan India Transactions. The E-FPB will have to open accounts under each major head for all governments. Total 38 accounts (one each for CGST, IGST and one each for SGST for each State/UT Govt.) will have to be opened. Any amount received by such E-FPB towards GST will be credited to the appropriate account held by such E-FPB. For NEFT/RTGS Transactions, RBI will act as E-FPB.

Can I upgrade my subscription?

Yes, as on when your invoice volume increases or addition more companies or GSTNs, you can move to higher subscription

What happens to my data when I cancel my subscription?

Once you’ve cancelled the subscription, all your existing data will remain in read-only mode. f you wish to backup your data, you can export your data in CSV or XLS formats.

Will I get refund if I cancel during subscription period?

Yes, refund will be calculated on a prorated basis and monthly charges will be applied for already completed months and remaining amount will be refunded.

Will the cost of my subscription increase?

The cost of an annual subscription will not increase in the year you are subscribed. The cost of a month-month subscription can change. In this situation, when there is change you are notified in advance and are given the option to cancel or move another subscription.

Who can generate the IRN from the e-invoice system?

Presently, IRN can be generated only by the tax payers who have been notified. That is, tax payers whose turnover is more than Rs. 500 Crores.

How many rounds of testing of APIs have to be made on the sandbox system to get the production access?

All APIs have to be tested on the sandbox environment. Each API with at least 50 success cases and 50 failed cases with different errors to be tested. The system generated MIS report will be provided under ‘API developer testing’ application to find out how many cases are tested by the tax payers. Based on this report, the system will declare whether tax payer is qualified for production access or not.

Which is the algorithm used for encryption and decryption of data?

The asymmetric algorithm (RSA/ECB/PKCS1Padding) and symmetric algorithm AES256 (AES/ECB/PKCS5Padding) along with SEK is used to encrypt the request payloads of the POST API methods and to decrypt response payloads. It may be noted that SEK is generated and passed by the e-invoice system while sending the authentication token.

Whether e-invoice generated is also required to be signed again by the taxpayer?

  1. Signing of invoice is required by the rules notified by the Government of India. A placeholder for digital signature has been added in the e-invoice schema and hence if a signed e-invoice is sent to IRP, the same will be accepted.
  2. The e-invoice will be digitally signed by the IRP after it has been validated. The signed e-invoice along with QR code will be shared with creator of document as well as the recipient.
  3. Once it is registered, it will not be required to be signed by anyone else.

Can the seller place their LOGO in the e-invoice template?

  1. There will NOT be a place holder provided in the e-invoice schema for the company logo.
  2. This is for the software company to provide in the billing/accounting software so that it can be printed on his invoice using his printer. However, the Logo will not be sent to IRP. In other words, it will not be part of JSON file to be uploaded on the IRP.

Is there any change in the e-way bill generation after introduction of e-invoice system?

  1. As of now, there is no change in the generation of e-way bill process. It will exist along with the e-invoice system. There will be additional facility in future to generate the e-way bill based on the IRN.

Can I generate e-way bill using IRN?

  1. Yes, there will be one more API, released shortly, to generate the e-way bill based on IRN and Part-B details.

At present the e-Invoice API is for those GSTIN where turnover is > 500 crore. What about small traders? Please let us know if you planning to have an offline tool for preparing e-Invoice? Or developing the URL where we can enter the data for generation of e-Invoice.

As of now, the criteria for e-Invoice is turnover greater than 500 crore. There will be government notifications on the change in eligibility criteria. Yes, there will be offline tool and web portal.

Should we whitelist our IPs to access Sandbox APIs?

There is no need for whitelisting the IPs to test on the Sandbox.

How do the customers and GSPs test the APIs?

Testing can be done using GSPs virtual GSTINs for different states.

E-invoice system is showing my old email id or mobile number. How should I get it changed?

E-invoice system is using the email id and mobile number, registered by the taxpayer on the GST Common Portal, for communication purpose. If it is old, get is updated with latest on the common portal and communicate to us at support.einv.api@gov.in so that we can cross-verify and update on the sandbox for accessing the credentials. If you are a GSP, then get it updated with GSTN and request them to communicate to us so that it can be updated.

My one business unit has GSTIN in each state based on same PAN. Can I use same API credentials to access to the API system?

There are two types of API credentials – Client Id and Client Secret, and Username and Password. Client Id and Client Secret is provided to the notified tax payer and the tax payer can use it for all the business units registered in different states, based on the same PAN. Whereas the Username and Password is created for each GSTIN. That is, one business, registered in different states, need to create separate username and password for each registered unit/GSTIN.

What if email id and mobile number is not matching?

Make sure you use the email id and mobile number entered by you in the GST portal.

For Sandbox testing of E-Invoicing at the time of registration it is giving message that: "Sorry Your GSTIN is not Shortlisted for E-Invoice API."

Presently it is activated only for GSTINs with turnover more than 500 crore. In case you come under this category, contact GSTN.

How and where can I get the credentials to access the APIs?

GSP and tax payer can get the API credentials using the online registration option under ‘Login’ system on this portal.

Where can I get the URL or end points of APIs?

On logging into the testing portal, one can get the end points of APIs for sandbox system.

Where can I get the Public Key of e-invoice system?

On logging into the testing portal, one can get the public key of the e-invoice system for sandbox system.

Do I need to generate the token for each transaction or request?

It is not advisable to request for new token before firing each transaction. Once the token is generated it can be re-used any number of times till it get expired. Even if new request for token is made, the system returns the already generated valid token with an expiry time. The best practice is, once the token is generated, store in the tax payer system along with SEK and expiry time. Next, whenever the transaction request is made, token can be referred from the system and used. If it has expired, then request for new token and store and use it.

What happens if the same request or same transaction is fired multiple times?

It is not advisable to send the same request or same transaction continuously or multiple times. However, based on the response of the transaction, the tax payer system to act upon rather than firing again. If it happens so, then the e-invoice system will block that user’s requests for one hour and so.

What is the purpose of the parameter “ForceRefreshAccessToken” in authentication API?

ForceRefreshAccessToken parameter of Authentication API can be used by the tax payer system to generate the new token, just 10 minutes before the expiry of the token. Basically, the tax payer system can use it to avoid failure of the transaction fired after expiry of the token.

What is the validity of the authentication token?

Authentication token generated by the e-invoice system is valid for 6 hours on the production system. However, for effective testing by the developer, it has been set for 1 hour in the sandbox.

Who has to generate the Appkey?

Appkey is generated by the API consuming application. It is a 32 byte AES key.

As you have mentioned in the FAQs that “Both e-way bill and e-invoice co-exist and the authentication token generated on one system can be used with other system within the expiry time”. Does that mean the GSP/ASP use the e-Way Bill username and password of the taxpayers (generated in e-Way Bill system while registering our GSP) in the e-Invoice portal to generate the authtoken?

In case the tax payer is using the API through GSP, the GSP will provide the ClientId and ClientSecret to the tax payer. GSP will not have the taxpayer’s user id and password. On the production environment (when made available), if the taxpayer has generated the token using a set of credentials (client Id, GSTIN, user Id, password) using one system, then same token can be used for calling other system API. In Sandbox, the credentials are different for each service.

We are getting error while decrypting SEK. We are doing it using App key. JAVA Error is: java.security.InvalidKeyException: Invalid AES key length: 44 bytes. Please help.

App key should be byte array (byte[ ]) of 32 bytes length e-invoice API.

How to decrypt the SEK received?

Same App Key that was sent in auth request only needs to be used to decrypt the SEK that has come as the response to the API call using Symmetric AES algorithm.

Where to get the public key for encrypting the password and App key?

Please log in to https://einv-apisandbox.nic.in/einvapiclient/ using your generated credentials. To the right side, you will get an option to download the public keys.

Whether the IRN is to be captured in the Supplier’s ERP?

  • The IRN (hash) will be generated by IRP (register) using GSTIN of supplier or document creator, financial year and the unique serial number of the document/ invoice along with the document type.
  • The serial number of invoice must be unique for a GSTIN for a Fin Year and the same has to be captured by Supplier’s ERP.
  • Supplier has to keep the IRN against each of its invoice, once received by the seller from the IRP. It will be advisable to keep the same in the ERP as invoice without IRN will not be a legal document.

There are certain fields today which are optional and some mandatory. How are these to be used?

  • The mandatory fields are those that MUST be there for an invoice to be valid under e-Invoice Standard.
  • The optional ones are those that may be needed for the specific business needs of the seller/business. These have been incorporated in the schema based on current business practices in India.
  • The registration of an e-invoice will only be possible once it has ALL the mandatory fields uploaded into the Invoice Registration Portal (IRP).
  • A mandatory field not having any value can be reported with NIL.

I am trying to generate IRN from einv-apisandbox.nic.in. However I am getting error code 5001 every time with following detail: {"Status":0,"ErrorDetails":[{"ErrorCode":"5001","ErrorMessage":"Application Error, Please Contact the help desk Padding is invalid and cannot be removed.`]}`,"Data":null}

Please check whether the encryption is happening correctly using the decrypted SEK. You may use the facility in the developer test portal where you can encrypt the same payload using the decrypted SEK and compare the encrypted output from your function with same payload and SEK.Make sure you have decrypted the SEK received using the App key using symmetric algorithm before using the same as key for encryption.

We are able to consume the e-invoice API. However we are stuck in decrypting the Generate IRN Response. Please help.

The details are provided in the API documentation along with sample code in C# and Java at https://einv-apisandbox.nic.in/ The response is encrypted using the SEK using symmetric algorithm, so please decrypt using the SEK.

e-Invoice/ Generate IRN API allows for maximum of 1000 line items per document whereas Generate e-Way Bill API allows maximum of 250 line items per document. Can you please confirm whether Generate e-way bill API will be changed now to sync allowing of line item count in e-way Bill APIs?

e-Invoice will have 1000 line items, and when the e-way bill generated from it, e-way bill have high value 250 items with total invoice value. This is followed in current e-way bill system also.

Could you please let us know if taxpayer system could generate the IRN on their own using the SHA256 algorithm logic (or) we need to mandatorily get the information from IRP.

Just generation of IRN is not the goal of the e-Invoice system. Registering the invoice with the IRP is the actual requirement (Given the logic of generation of IRN, anybody can generate it, but unless it is registered, it has no authenticity). As the IRP anyway has to generate the IRN (atleast to check whether tax payer generated IRN is correct), there is no need to generate IRN by tax payer.

Should there be a space provided for the QR Code in the e-invoice?

  • The QR code will be provided to the seller once he uploads the invoice into the Invoice Registration system and the same is registered there.
  • Seller must print the QR code on the printed Invoice.

We successfully generated e-Invoice and got SignedInvoice, SignedQRcode raw data. Going further please help us to decode and verify the signature.

The data is signed using JSON Web Signature, details can be obtained from the web. The signed token has 3 parts, header, data and signature, these three are separated by (dot). After splitting the 3 parts, you can decode the first 2 parts of content with base64 decode.

Will there be any mechanism/platform provided to taxpayers to view/validate Signed QR Code's data in plain text and confirm whether it is an authentic IRP registered IRN or not ?). After splitting the 3 parts, you can decode the first 2 parts of content with base64 decode.

There will be provision to validate the QR code off line, as well as there will be facility to upload the signed QR code to the portal and get it verified. Details will be shared later.

Do we need a public JWK set to verify this JWT? If yes how can we access the public JWK set?

To verify the signed Invoice and the QR code, the public key of the certificate which is used to sign is required. This public key is same as that has been used for encrypting the password and App key. The key for sandbox environment is available for download in the e-Invoice sandbox API developer’s portal.

Please suggest whether QR Code of signed data needs to be printed or QR Code of decoded data must be printed for B2B(Business-to-Business) E-Invoice PDF to be issued/ maintained/ shared by suppliers having turnover of more than 500 crore with their buyers?

Signed QR Code data, passed as the response of IRN generation, has to be printed along with the signature on the invoice. You can see these QR code on the web version of e-invoice system that is, going to be released shortly.

There is no version number in API end points, is this final or in future you are going to introduce versions?

As of now, in the trial, there is no version number. In future, version number would be part of the end point for subsequent versions.

Taxpayers or the GSPs will be allowed to access the production environment by whitelisting maximum upto 4 Indian static IP addresses. For production, if we don’t have a static IP address, is there any alternative to access to the GST network? Is it a mandatory requisite?

For production, access is allowed only through the white listed IP addresses of India.