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India

Guidelines for storing e-invoices in India, covering GSTIN separation, CTC e-invoicing, and compliance with Indian GST rules.

GSTIN Separation

If an Indian taxpayer stores e-invoices for multiple companies and/or tax registrations, the companies and/or tax registrations should be created as separate companies within Sovos eArchiving. In practice, this means that each GSTIN number must be created as a separate company so that the invoices are stored in a separate archive.

CTC e-Invoicing

As India has mandated e-invoicing for certain taxpayers, there are two different components to be stored depending on the processing of invoices. For taxpayers subject to the clearance regime, the main document that should be stored with Sovos eArchiving is the signed JSON, as it proves successful clearance by the IRP (See e-invoicing compliance India page for more information). It's also highly recommended to store the PDF as a human-readable copy for audit purposes. Additionally, responses received from the IRP portal must be stored (the QR code data, AckNo, AckDt).

If the signed JSON is converted into the PDF and then exchanged with the buyer, the PDF invoice must also be stored, either as the main document and the signed JSON as the attachment, or vice versa.

If taxpayers can't submit JSON files to the IRP during the grace period, PDF invoices must be stored as the main document. Once the JSON is successfully submitted within 30 days, it should be stored as an attachment, along with the other responses received from the clearance portal.

To store an Indian CTC e-invoice, the customer should set the Archiving.DocumentFormat scope to "INIDJSON", the Archiving.SignatureType scope to "Audit" and the Archiving.SignatureFormat scope to "INJWS", within the SBDH. The DocumentIdentification.InstanceIdentifier parameter in the SBDH should be populated with the invoice number, as specified in the DocDtIs.No parameter within the JSON.

The IRN should be set as an Archiving.CustomProperty scope in the SBDH. Alternatively, the IRN could be set as the DocumentIdentification.InstanceIdentifier parameter and the invoice number as Archiving.CustomProperty scope. Furthermore, the AckNo and AckDt -- as returned in the signed JSON and in the application response -- should be set as Archiving.CustomProperty scopes. In case an e-waybill has been generated as part of the invoice clearance transaction, the EwbNo, EwbDt, and EwbValidTill -- as returned in the signed JSON and in the application response -- should also be set as Archiving.CustomProperty scopes. If an e-waybill has been generated, and the related invoice has already been stored, the EwbNo, EwbDt and EwbValidTill information should be added to the stored invoice via an Update Invoice request -- whereby the aforementioned information will be included as Archiving.CustomProperty scopes. Alternatively, the application response resulting from the e-waybill generation transaction could be attached to the invoice via an Update Invoice request.

The SignedQrCode data included in the application response returned from the clearance process should be stored as an attachment to the invoice.
Note:

Cancelled invoices and e-waybills should not be deleted from the archive, but must be stored there along with the response, as a result of the cancellation. This can be done by attaching the application responses generated by the cancellation transactions to the archived invoice using an Update Invoice request, or by adding the CancelDate information to the archived invoice as Archiving.CustomProperty scopes.

GST Rules (Non-CTC)

There's a specific process for taxpayers who are not in the scope of CTC e-invoicing. As per Indian GST (previously CENVAT) rules, invoices must be issued in three copies:
  1. ORIGINAL FOR BUYER

  2. DUPLICATE FOR TRANSPORTER

  3. TRIPLICATE FOR ASSESSEE (supplier)

Therefore, GST invoices may need to be issued in three copies, with at least the first copy for the buyer and the third copy retained by the supplier digitally signed (see the post-audit page for more information). Note that this rule is waived for the clearance process and therefore only applies to invoices that don't require clearance. The second copy is typically presented in paper form during transportation; optionally, the second copy can also be issued and signed electronically.

If either the supplier or the buyer wishes to archive the transport invoice, it's possible to do that as an attachment to the respective party's e-invoice. The attachment can either be stored with each invoice in the Store Invoice request, or be added later via an Update Invoice request.

Storing in India

Several sectors, including financial services, must store their invoices on Indian soil according to the Indian laws. Sovos eArchiving offers the possibility to store invoices in datacenters located in India. This functionality can be configured per area or per company.
Note:

This is a custom configuration that must be configured by Sovos and is subject to separate terms. To get started, send a request to europesupport@sovos.com.

GSTIN Check

It is recommended to archive the evidence of GSTIN checks. You can store the response payload as an attachment to the invoice, or alternatively the response payload can be stored as the main document.