Honouring a voucher creates an additional burden of GST Published on: 29 Dec, 2021

RAJ KUMAR SINGH

Publishing, Literature, Editing

Mistaken opinion seems to be prevailing in some quarters that if GST is paid on the vouchers, then the GST to the extent so paid will not be required to be paid again on the supply of goods/services received thereagainst.

2. Voucher is defined in section 2(118) of CGST Act, 2017 as under:

s.2(118) "voucher" means an instrument where there is an obligation to accept it as consideration or part consideration for a supply of goods or services or both and where the goods or services or both to be supplied or the identities of their potential suppliers are either indicated on the instrument itself or in related documentation, including the terms and conditions of use of such instrument; 

Thus, a voucher is a mode of payment or part payment for the supply of goods/services received.

2. The time of supply of voucher where the 'supply' is identifiable (so-called single purpose voucher) is the date of issue (Refer s. 12(4)(a) or s. 13(4)(a) ibid). It means that the invoice issued to an unregistered individual for a voucher of face value of Rs.2000/- supplied at par will be for Rs.2000 + the GST applicable. This GST will be obviously required to be paid to the Government by the supplier of the voucher.

3. When this voucher worth Rs.2000/- is presented for receiving supply of the eligible goods by an (unregistered) individual, the supplier of the goods will issue the usual invoice showing the value of the goods plus GST and ask the said individual to pay the difference (beyond Rs. 2000/-) taking the voucher as part consideration. There is no legal provision under which the supplier of the goods will be able to offset the GST paid on the voucher against the GST payable on the goods. Needless to say that GST payable on the supply of the goods will have to be paid by the supplier of the goods to the government.

4. It is pertinent to mention that supplier of the voucher and the supplier of the goods thereagainst need not be the same (legal) person but even if both are the same, that would make no difference and GST on the said amount of Rs.2000/- will, in effect, end up being paid to the government twice because the GST so paid twice on the said sum of Rs.2000/- will not be available as input tax credit to anyone.

5. The scenario depicted above applies mutatis mutandis to multipurpose vouchers, the only difference being in the time of supply, which in the case of multipurpose vouchers, is the date of redemption (Refers. 12(4)(b) and S. 13(4)(b) ibid) but that only makes a difference to the due date (and not the quantum) of payment of GST.

6. It is, therefore, necessary for the assessees to beware that use of vouchers as a marketing strategy would aggregately result in additional burden of GST.


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