Debit Note in GST vs Accounts

CA Arun Chhajer , Last updated: 02 May 2019  
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DEBIT NOTE

Meaning

In Accounts ,Debit Note can be raised either by Supplier or by Recipient. However as per Section 34 of CGST Act 2017, Debit Note can only be issued by the Supplier to the recipient. In other words, we can say that a Debit note cannot be raised by the recipient in GST.

Situation Where Debit Note is to be issued

A supplier of goods or services or both is mandatorily required to issue a tax invoice. However, during the course of trade or commerce, after the invoice, Debit Note can be issued in the following situations like:

• The supplier has erroneously declared a value which is LESS THAN the actual value of the goods or services or both provided.

• The supplier has erroneously declared a lower tax rate than what is applicable for the kind of the goods or services or both supplied.

• The quantity received by the recipient is more than what has been declared in the tax invoice.

• Any other similar reasons.

As per the Explanation to Section 34 of CGST Act 2017, For the purposes of this Act, the expression 'debit note' shall include a supplementary invoice.

Contents of Debit Note - Format of Debit Note has not been prescribed. However we need to refer Sub Rule (1A) of Rule 53 of CGST Rule for the prescribed content of a Debit Note-

(a) name, address and GSTIN of the supplier;

(b) nature of the document;

(c) a consecutive serial number not exceeding sixteen characters, in one or multiple series, containing alphabets or numerals or special characters-hyphen or dash and slash symbolised as '-' and '/' respectively, and any combination thereof, unique for a financial year;

(d) date of issue of the document;

(e) name, address and GSTIN or UIN, if registered, of the recipient;

(f) name and address of the recipient and the address of delivery, along with the name of State and its code, if such recipient is un-registered;

(g) serial number(s) and date(s) of the corresponding tax invoice(s) or, as the case may be, bill(s) of supply;

(h) value of taxable supply of goods or services, rate of tax and the amount of the tax credited or, as the case may be, debited to the recipient; and

(i) signature or digital signature of the supplier or his authorised representative.'

Whether Consolidated Debit Notes are Permitted?

As per CGST( Amendment)Act,2018 with effect from 01.02.2019 the following changes have been made in Section 34 of CGST Act

(i) for the words 'Where a tax invoice has', the words 'Where one or more tax invoices have' shall be substituted;

(ii) for the words 'a debit note', the words 'one or more debit notes for supplies made in a financial year' shall be substituted.

Prior to GST Amendment Act 2018, a registered person is required to issue one debit note for each invoice. However, after GST Amendment Act 2018 (effective from February 1, 2019), a registered person can issue consolidated debit note in respect of multiple invoices issued in a financial year without linking the same to individual invoices.

Time Limit for declaration of Debit Note (Section 34(4) of CGST Act 2017)

Any registered person who issues a debit note in relation to a supply of goods or services or both shall declare the details of such debit note in the return for the month during which such debit note has been issued and the tax liability shall be adjusted in such manner as may be prescribed.

Whether above changes are reflecting in the GST portal?

The changes were not incorporated in the GST Portal from 1st Feb 2019 even though amendment was made in the Act.

Disclosure of Debit Note in GSTR-1

It is to be disclosed in Table 9B of GSTR 1. It captures information for original debit note issued.

Amendment of Debit Note in GSTR-1

Debit Note which has been disclosed in the Table 9B can be amended in the subsequent period. Amendments to such information is reported in Table9C of GSTR1.

Disclosure of Debit Note in GSTR-3B

Debit Note is to be shown in GSTR 3B Table 3.1.A i.e. Outward taxable supplies (other than zero rated, nil rated and exempted) by adding it to the outward supply.

Relevant Extract of GSTR 1 Table 9B

Relevant Extract of GSTR 1 Table 9C

Relevant Extract of GSTR 3B Table 3.1.A

Note - The above article is only for education purpose.

The author can also be reached at arunchhajer@gmail.com

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Published by

CA Arun Chhajer
(GST Faculty @ Ministry of MSME Govt of India)
Category GST   Report

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