Sir
We are suppliers of automobile components to various clients.
We supply them based on orders received on a regular basis. The price is ascertained mutually between the supplier and the client based on the input viz. steel. We continue supply based on the agreed price and over a period of time due to the fluctuations of the price of steel and other commercial reasons, the cost of the components would change either high or low and once in six months, the final prices would be agreed to.
While issuing a debit note for the differential price due to upward revision, it becomes necessary to issue a debit notes for the entire invoices issued during the period and in case of downward revision, it becomes necessary to issue credit notes for each and every invoice during the period which is a cumbersome process. The supplier issues a consolidated debit/credit notes which does not figure in the GSTR-2A consequently the ITC credit would be denied.
Considering the volume of invoice for a period of 3 months, there would be approx. 2000-3000 invoices for which debit notes/credit notes would have to be issued.
I would be grateful if some of the experts can comment on the above and if there is provision in the Act and Rules for acceptance a consolidated credit or debit notes.
Thank you