QR Code for B2C Invoices: “Digital Display” for Customers?

B2C (or Business to Customer) Invoices are those where the buyer is the end user who will not be claiming Input Tax Credit (ITC) from GSTN. As per the Notification published after the 39th GST Council meeting held on 14th March 2020, the government has made it mandatory for businesses with turnover greater than 500 Crore to display QR Code on their B2C Invoices too.

The QR Code can be scanned to extract information as under:-

  • GSTIN of the supplier
  • GSTIN of the recipient
  • Invoice number given by the supplier
  • Date of the generation of invoice
  • Invoice value
  • Number of line items
  • HSN Code of the main item
  • Unique Invoice Reference Number/Hash

However there is an ambiguity in the following explanation indicated in the Notification:- Notification No. 14/2020– Central Tax

“Provided that where such registered person makes a Dynamic Quick Response (QR) code available to the recipient through a digital display, such B2C invoice issued by such registered person containing cross-reference of the payment using a Dynamic Quick Response (QR) code, shall be deemed to be having Quick Response (QR) code.”

In the above, the “registered person” is the seller who has been assigned a GST Number, while the “recipient” is the buyer who is not registered with GSTN.

Normally, a QR Code printed on a Bill is static, and its content cannot be changed after the Bill is handed over to the customer. However, here the requirement seems to be to provide a “Dynamic QR Code” through a “digital display”.

This would mean that the dynamic QR Code in every printed Bill given to the buyer must contain the link to a URL using which the buyer can navigate to the “digital display” indicating the payment status (“cross-reference”) of the Bill

If this interpretation is correct, then every Company with aggregate turnover over Rs 500 Crore that needs to issue B2C Invoices with effect from 01 Oct 2020 will need to have a cloud based software application which will provide the “digital display”

using which their retail customers (or tax officials) can view the payment status of B2C Invoices.

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