Advisory 547 on Invoice Management System (IMS): Ensuring Accurate ITC and Liability in GSTR-3B during initial phase of Its implementation

Taxpayers can update the action taken on the Invoice Management System (IMS) (e.g., changing an invoice from “rejected” to “accepted” or vice versa) and recompute GSTR-2B anytime before filing GSTR-3B

Starting October 2024, the GST Portal introduced the Invoice Management System (IMS), an optional tool designed to streamline the process of verifying invoices and tax credits. This innovative system allows recipients to accept, reject, or keep pending any invoices or records uploaded by suppliers in GSTR-1/1A/IFF. The actions taken on IMS directly influence the recipient’s GSTR-2B report, which is generated on the 14th of the following month.

Here’s how taxpayers can benefit from and navigate IMS effectively to ensure accurate tax filings.

Also Read: Karnataka High Court Rejects Ex-Parte Order Due to GST Department’s failure to Notify Personal Hearing Dates via email, Despite a Clear Request

Key Functions of the Invoice Management System

The IMS allows taxpayers to take specific actions on invoices:

  • Accept: Confirms the invoice and includes it in GSTR-2B, which reflects the eligible input tax credit (ITC).
  • Reject: Excludes the invoice from ITC eligibility in GSTR-2B.
  • Pending: Marks the invoice for further verification.

Once an invoice is accepted, rejected, or pending, the recipient’s GSTR-2B will auto-populate these statuses. Furthermore, the GSTR-3B form on the GST Portal will reflect the ITC and tax liabilities as per GSTR-2B, although taxpayers have the flexibility to edit these auto-populated fields before finalizing and filing GSTR-3B.

Also Read: GST Waiver Scheme Under Section 128A for FY 2017-18 to 2019-20: How to Avail Relief on Interest & Penalties

Correcting Errors in the Initial Phase of IMS Implementation

During the initial rollout of Invoice Management System, taxpayers might inadvertently make mistakes when marking actions on invoices. Such errors can impact:

  • ITC Availability: Incorrect rejection or acceptance in IMS can alter the accurate reflection of ITC in GSTR-2B.
  • Liability Auto-population: Mistakes in IMS may lead to inaccurate liability data for both the recipient in GSTR-3B and the supplier.

If such mistakes are identified, taxpayers can update the action taken on the Invoice Management System (IMS) (e.g., changing an invoice from “rejected” to “accepted” or vice versa) and recompute GSTR-2B anytime before filing GSTR-3B. This ensures that GSTR-3B accurately reflects the correct ITC and tax liabilities.

Also Read: Suspension of GST Registration Directly Without Initiating Civil or Criminal Proceedings Violates Fundamental Right to Trade: Madras High Court

Recommended Actions for Taxpayers Using IMS

In cases where errors in IMS actions lead to incorrect ITC or liability figures in GSTR-3B, taxpayers are advised to:

  1. Review Auto-populated Data: Before filing GSTR-3B, carefully review the ITC and liability details auto-populated from GSTR-2B.
  2. Edit as Needed: If discrepancies are found due to IMS actions, edit GSTR-3B entries manually to ensure correct ITC availing or accurate tax liability based on actual records.
  3. Verify with Documentation: Always cross-check ITC and liabilities with available records to avoid discrepancies.

By following these steps and leveraging the flexibility of Invoice Management System (IMS), taxpayers can reduce filing errors and ensure their GSTR-3B accurately represents their tax obligations and eligible input tax credit.

Access the Advisory 547 in GST Portal

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