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Recent advisories relating to reporting an e-invoice on the IRP portal and HSN code

Recently GSTN has come up with two important advisories one relating to reporting an e-invoice on the Invoice Registration Portal (IRP) and the other relating to the HSN code reporting requirement. The same is –

Advisory relating to HSN code reporting in an e-invoice on IRP issued on 22^nd March 2023; and
Advisory relating to the time limit for reporting an e-invoice on IRP issued on 12^th April 2023. The said advisory was updated on 13^th April 2023.

Both the said advisories are briefly explained in the current article.

Advisory relating to HSN code reporting in an e-invoice on IRP –

Notification no. 78/2020 – Central Tax dated 15^th October 2020 came up with the requirement of mentioning of HSN (Harmonized System of Nomenclature) code on the tax invoice. The said requirement is tabulated hereunder –

Particulars	Number of Digits of HSN to be mentioned on the tax invoice
Aggregate turnover in the preceding Financial Year is up to INR 5 Crores	4
Aggregate turnover in the preceding Financial Year is more than INR 5 Crores	6

Notably, mentioning of HSN in the case of a registered person having aggregate turnover in the preceding Financial Year up to INR 5 Crores is not mandatory.

Taking a step ahead, the above HSN requirement in the case of the aggregate turnover of more than INR 5 Crores is likely to be implemented at the IRP portal. An Advisory for the same is issued on 22^nd March 2023. The advisory states as under –

Six-digit HSN code, in the case of a registered person having an aggregate turnover of more than INR 5 Crores, is to be implemented in the IRP portal;
It is clarified that in case a valid six-digit HSN is not available, instead of entering an artificially created HSN code, an eight-digit HSN code should be reported;
Advisory states that as the above requirement needs some system change, sufficient time will be provided to both the taxpayers as well as the IRP partners. Accordingly, the date of implementation of the HSN code in the IRP portal will be communicated shortly.

Advisory relating to the time limit for reporting an e-invoice on IRP –

As we know, e-invoicing is implemented under Goods and Services Tax (GST) in a phase-wise manner. The following table briefly summarizes the phases of e-invoice implementation –

Phase	Applicability of e-invoice	Relevant notification no. and date
1^st Phase	Mandatory e-invoice in case of a registered person having an aggregate annual turnover of more than INR 500 Crores in any previous Financial Year with effect from 1^st October 2020.	Combine reading of notification no. 13/2020 – Central Tax dated 21^st March 2020 and notification no. 61/2020 – Central Tax dated 30^th July 2020
2^nd Phase	Mandatory e-invoice in case of a registered person having an aggregate annual turnover of more than INR 100 Crores in any previous Financial Year with effect from 1^st January 2021.	Notification no. 88/2020 – Central Tax dated 10^th November 2020
3^rd Phase	Mandatory e-invoice in case of a registered person having an aggregate annual turnover of more than INR 50 Crores in any previous Financial Year with effect from 1^st April 2021.	Notification no. 05/2021 – Central Tax dated 8^th March 2021
4^th Phase	Mandatory e-invoice in case of a registered person having an aggregate annual turnover of more than INR 20 Crores in any previous Financial Year with effect from 1^st April 2022.	Notification no. 01/2022 – Central Tax dated 24^th February 2022
5^th Phase	Mandatory e-invoice in case of a registered person having an aggregate turnover of more than INR 10 Crores in a Financial Year with effect from 1^st October 2022.	Notification no. 17/2022 – Central Tax dated 1^st August 2022

Notably, till now, there was no time limit for reporting of an e-invoice on IRP. However, with the issuance of a recent advisory, an e-invoice needs to be reported within a period of 7 days on the IRP.

The advisory was issued on 12^th April 2023 which was later on updated on the very next day i.e. 13^th April 2023. The said advisory is briefly summarized hereunder –

Time limit is introduced in case of reporting of old invoices on the e-invoice Invoice Registration Portal (IRP);
The said time limit for reporting of old invoices on e-invoice IRP is applicable only to the taxpayers having Aggregate Annual Turnover (AATO) more than or equal to INR 100 Crores;
The invoice on the e-invoice IRP is to be reported within a period of 7 days from its issuance;
The taxpayer will not be allowed to report the invoice which is older than 7 days from the date of reporting of the invoice;
The reporting restriction is applicable to all the types of documents i.e. invoice, credit note and debit note;
The reporting restriction will be made effective from 1^st May 2023.

Let us understand the advisory with the help of the table below –

Registered person having AATO of more than INR 100 Crores

Registered person having AATO of less than INR 100 Crores

Invoice date – 1^st May 2023

E-invoice reporting restriction – Applicable

Maximum date by which e-invoice needs to be reported – 8^th May 2023

Invoice date – 1^st May 2023

E-invoice reporting restriction – Not Applicable

Maximum date by which e-invoice needs to be reported – Not time limit

Concluding thereby that as e-invoice is implemented in a phase-wise manner, the Government is trying to implement a time limit for reporting e-invoice on IRP also in a phase-wise manner. The 1^st phase of the same covers registered person having AATO of more than INR 100 Crores.

Synopsis of both the advisories –

The following table summarizes both the advisories –

Particulars	Advisory issued on 22^nd March 2023	Advisory issued on 12^th April 2023 and updated on 13^th April 2023
Matter covered	HSN code reporting in an e-invoice on IRP portal	Time limit for reporting of an e-invoice on IRP portal
Applicable to	Registered person having an aggregate turnover of more than INR 5 Crores in the preceding Financial Year.	Registered person having an aggregate annual turnover of more than or equal to INR 100 Crores.
Reporting time	Not specified	Within 7 days of the issue of invoice, credit note or debit note.
Implementation date	Not specified	1^st May 2023