Issuing debit credit note under GST for sales made before gst registration or for sales form old entity (in case of business transfer)

Hi Friends,

Can someone confirm below response I recceived from CBEC Mitra Helpdesk?

I called CBEC Mitra Helpdesk on 18001200232 a few minutes back, and I was informed as follows:

1. For Credit Notes issued after getting registered under GST, we are required to levy GST on all Credit Notes & Debit notes, even if original sales/supplies (related to such credit note being issued) was made BEFORE GST registration, as an unregistered dealer, without applying GST. Also, such credit notes will be reported under GSTR-1 and they should NOT be marked as "Pre-GST" if original sales/supplies were made on / after 1st July 2017 (in short, "Pre-GST" does NOT mean pre-registration).

2. Also, if there is transfer of business from one entity to another entity, then, for sales/supplies made in old entity, you can issue debit/credit notes (after the business transfer date) from the new entity. And such debit / credit notes should be reported under GST returns of the new entity.

Thanks,

Narendra