Auto-population of E-Invoices into GSTR-2A/2B through GSTR-1
Invoices once auto-populated into GSTR-1 will auto-populate in recipient’s GSTR-2A as well on near real time basis as GSTR-1 and GSTR-2A flow works on real time basis. However, in recipient’s GSTR-2B it will auto-populate after filing of GSTR-1 of supplier (data already prescribed i.e. 13th of succeeding month).
Same like GSTR-1, in GSTR-2A and GSTR-2B also IRN Number, IRN date and Source Type of IRN auto-populates.
Instead of auto-population, the recipient cannot claim ITC blindly based on Invoices reflecting into GSTR-2A & 2B, it has to be assured by the recipient that invoices reflecting into GSTR-2A/2B are valid invoices.
There are some challenges, which taxpayers are facing while claiming ITC on the basis of GSTR-2A/2B, few of them are listed below:
Challenges while claiming Input Tax Credit from auto-populated data and corresponding impact
1. How to Identify Non-compliant supplier –
Govt. have provided a list of suppliers with a GSTIN number for which E-Invoice is mandatory. So, if any of your vendor is coming in that list and IRN information is not coming in invoices auto-populating in GSTR-2A and 2B along with other invoice details received from such vendor then it might be a situation that respective vendor is non-compliant.
Suggestion –from Business point of view purchasing activities from such vendors should be stopped.
List of such vendors can be fetch out from below link https://einvoice1.gst.gov.in/Others/GSTINsGeneratingIRN
2. How to Identify Invalid Invoices –
In continuation of above point, invoices, which are received from non-compliant suppliers, will be invalid invoices because according to Rule 48(4), notified persons have to issue invoice in e-invoice format and according to Rule 48(5) invoice issued other than, any manner as specified in Rule 48(4) shall not be a valid invoice.
There could be a scenario where the supplier is saying he has generated e-invoice but same in not auto-reflecting in GSTR-2A/2B whether it is possible?
Solution- It could be a scenario where the details auto-populated into GSTR-1 from e-invoice have changed/edited/re-uploaded/deleted due to any reason (for example- E-invoice generated with wrong details and 24 hours expired), in such case, “Source”, IRN Number”, and “IRN Date” will reset to blank and will not auto-populate to GSTR-2A/2B.
Hence, non-appearance of IRN details might be due to such kind of adjustments as well, that’s why authenticity of E-invoice can be verified by uploading signed JSON file or Signed QR code on e-invoice portal or secondly, QR code printed on Invoice copy can be verified through ,mobile app which is also available on Govt. Portal
Link of Verify signed JSON – https://einvoice1.gst.gov.in/Others/VSignedInvoice
Link of Downloading Mobile App – https://einvoice1.gst.gov.in/Others/QRCodeVerifyApp
3. Consequences of ITC Claimed in Invalid Invoices –
If ITC claims on any invoice which is received from a non-compliant supplier or against which IRN is not generated then the amount which is claimed will be considered as ITC against invalid and ineligible invoice hence ineligible ITC.
Government may charge interest against it, and ITC reversal rules will be applicable on such ITC.
However, Govt. have not provided any conclusive remarks upon it but for the safer side taxpayer should confirm on IRN applicability and generation before claiming ITC on such invoices.
Scenario taxpayers are facing –
As of now, there is no timeline on Generation of E-Invoice, so taxpayers are generating backdated e-invoices as well. If the buyer is claiming ITC on such invoices then interest can be charged by the government for such period i.e.(Date of ITC claim to Date of IRN Generation).
Auto-Populate in GSTR-3B –
GSTR-3B is auto-drafted by the government based on GSTR-2B, and e-invoice generated will auto-populate in respective month’s GSTR-2A and GSTR-2B. Indirectly E-Invoice once generated will auto-populate in recipient’s GSTR-3B as well.
Taxpayers have to be very conscious while claiming ITC against any invoice for avoiding later interest and penalties implications.