Flexibility of issuing single Credit/ Debit Notes against multiple invoices - Praiseworthy amendment

Pre-amendment, Section 34 of the CGST Act mandates a registered person to issue one credit/ debit note for each single invoice. Considering the woes of industries and to facilitate ease of doing business, amendment has been carried out in Section 34 of the CGST Act (effective from February1, 2019), which permits a registered person to issue consolidated credit/ debit note in respect of multiple invoices issued in a financial year without linking the same to individual invoices.

Comparative analyses of Section 34 of the CGST Act: Pre-Amendment v. Post-Amendment

Particulars	Before February 1, 2019	After February1, 2019
Section 34(1)of the CGST Act, relating to issue of ‘credit note’	'Where a tax invoice has been issued ................... may issue to the recipient a credit note containing such particulars as may be prescribed.'	'Where one or more tax invoices have been issued ............. may issue to the recipient one or more credit notes for the supplies made in a financial year containing such particulars as may be prescribed.'
Section 34(3)of the CGST Act, relating to issue of ‘debit note’	'Where a tax invoice has been issued ................... shall issue to the recipient a debit note containing such particulars as may be prescribed.'	'Where one or more tax invoices have been issued ............. shall issue to the recipient one or more debit notes for the supplies made in a financial year containing such particulars as may be prescribed.'

The above amendment is a boon for the taxpayers as the registered person can now issue a consolidated credit note or debit note against multiple tax invoices. Businesses can avail this facility to overcome the administrative challenges faced during linking the individual credit/ debit notes with their respective invoices earlier.

Corresponding amendment in the CGST Rules:

Corresponding to the above, amendments have also been incorporated in the CGST Rules, 2017 ('the CGST Rules' )vide Notification No. 03/2019- Central Tax dated January 29, 2019, effective from February 1, 2019.