Consolidated Credit Note

[Ramanathan PK]

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

[KASTURI SETHI]

The provision for issuing a single credit note with multiple invoice numbers has been made vide Notification No.3/19-CT dated 29.1.19 effective from 1.2.19. Peruse serial no.10 of the notification fully and word for word. Whether this facility/functionality has been activated on Common Portal System or not has to be checked. If not activated, make a representation to the concerned authority.

[PARUL SAXENA]

Still Portal is not updated with the provision so separate credit notes are required to be prepared..

[Ganeshan Kalyani]

Sir, the portal is not aligned with the provision. It will be aligned for sure as the provision is in place. Meanwhile, as an option, you may raise one single credit or debit note by giving reference of any one invoice number for the purpose of filing GSTR-1.

[KASTURI SETHI]

Rightly advised by Sh.Ganeshan Kalyani Ji. In the absence of functionality in Common Portal System, this is the only option for the time being.

[Ganeshan Kalyani]

Yes, Sir. Also, the time of the taxpayer is preparing so many credit notes will be done away with. However, listing of all invoice against with a single credit note is prepared should be kept in record safely.

AI Summary

Consolidated credit note permitted under GST; use single-note filing workaround and retain full invoice listing for ITC support. A notification allows issuance of a single credit note covering multiple invoice numbers, but the common GST portal may not support this functionality; until the portal is updated, taxpayers should prepare a consolidated credit or debit note for internal records, file GSTR-1 by referencing a single invoice number, and retain a full invoice listing to substantiate input tax credit claims and maintain audit trail.