GST draft invoice rules from perspective of system controls

CA.Rajeev Joshi (CA,CISA,DISA) , Last updated: 17 October 2016  
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Dear readers, the buzzword GST is humming every website, news channel, mobile app and newspaper. Digitization and System Controls are corner stone for success of GST.With recently released “Draft Invoice Rules”, it has become essential for all in accounting, systems and operations to ensure that the needed controls are in place which facilitate the smooth implementation of GST in respective organizations. Below are key points from System Control perspective that merit attention of relevant stakeholders. Below aspects may be examined based on the template which the existing “ERP or Accounting & Invoicing System” is using. In particular emphasis may be given to reviewing of the Automated System Controls for each of the below items:

a. Serial numbering of invoices - this should be automated, continuous, contain alphabet or numbers or alphanumeric, unique for a financial year.

b. Mechanism to track, upload and identify digital signature of supplier or his authorized representative.

c. Note that though the “Draft Invoice Rules” do not speak about any “special character” that may be contained in the invoice numbering system, however since the entire process at “Regulatory Authority Level” is heavily relying on system especially for “Invoice Matching” and “Credit based on payments” it seems ideally there be no “Special Character Use” in invoice numbering.  

d. System Identification mechanism to track the invoicing for unregistered recipient where taxable value of supply is more than Rs 50,000.

e. Correct updating the system for HSN Code for goods.

f. Correct updating the system for Accounting Code for services.

g. Mechanism for “Revision Of Invoices” / “ Supplementary Invoice” and does the System Control to ensure capturing “Date and Invoice Number” of original invoice.

h. System control to ensure that within 30 days of delivery of goods or rendering of services, the invoice is raised and accounted for. (45 days in case of financial institution/non-banking financial company /banking company).

i. System control to ensure that consolidated bill of supply are prepared by registered taxable person at the close of each day in case of all such supplies where bill of supply has not been issued.

j. System control for recording invoicing done during the period between effective date of registration and date of issuance of certificate of registration.

k. System controls for Input Service Distribution.

In the end meticulous examination of every screw and bolt in the functioning of the organization is going to contribute in successful implementation of GST, so lets get geared up.

The author is a Senior Financial Management & Control Professional with nearly two decades of comprehension industrial experience. and can also be reached at rajeevj12@gmail.com.

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CA.Rajeev Joshi (CA,CISA,DISA)
(Practice)
Category GST   Report

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