Lekhraj sood
Consequent to amendment to section 34 of CGST Act,2017 through CGST (Amendment) Act, 2018 which was made effective from February 1, 2019 , one credit note can be issued against one or more relevant tax invoices. Before this amendment, credit note/debit note could be issued only against one tax invoice, and giving reference to such a tax invoice was mandatory while reporting the debit/credit note in the GSTR1 on the GST Portal.
Though the above amendment was effective from 1st February 2019, the GSTN has given this facility to report a credit/debit on the GSTN portal now only. So, while reporting debit/credit note in GSTR1 no reference is required to be given of the original tax invoice/invoices. For example, if X ltd raised 25 invoices on Y ltd from April to September 2020 but now X ltd has to give credit note in the month of November 2020 due to price difference then X ltd can raise one credit note against all the supplies made vide 25 tax invoices. GSTN will not ask for a reference to the original invoices. The same would be the case for debit note.
Though delayed still a welcome change for the taxpayers.
However, it may be noted that where the credit note is on account of discounts covered discount the reference to original invoices must be maintained by the taxpayers as a record as this is a legal requirement under section 15. To reiterate, the text of Section 15(3) (b) is reproduced here-
" after the supply has been effected, if -
such discount is established in terms of an agreement entered into at or before the time of such supply and specifically linked to relevant invoices; and......."
Otherwise, also taxpayers are advised to keep complete backup calculations of debit/credit notes with reference to invoices for future audits and verification purposes.
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