QUESTION

Please guide what is the time limit to prepare e invoice in case of Debit / Credit note. Can we prepare the same on the last date of month?
We are manufacture of Polyester yarn and require to issue E Invoice compulsory as per the CBIC Provisions.

ANSWER

As per Rule 48(4) of the CGST Rules, a notified person has to prepare an invoice by uploading the specified particulars in Form GST INV-01 on the IRP, after obtaining an IRN. Rule 48(5) further states that any invoice issued by such notified persons in any manner other than the manner specified in Rule 48(4) shall not be treated as an invoice. Hence, an invoice or debit/credit note shall become legally valid only with an IRN.

However there is no validation kept on the portal to the effect that the 'document date' (in the payload to IRP) has to be within a specified time window, for reporting to IRP/generation of IRN', but it is not recommended because you will be violating the Time of Supply rules by doing so. Because, without an IRN, the invoice or debit/credit note on hand will not be valid. Hence, it is recommended to generate IRN's as and when invoice or debit/credit note are raised.   (Reply dt. 08/09/2021)