New Advisory on Invoice Management System (IMS) under GST

The Indian government, through the Goods and Services Tax Network (GSTN), has introduced a major enhancement to the GST portal with the launch of the Invoice Management System (IMS). This system aims to streamline the way taxpayers manage their invoices, making it easier to address discrepancies, ensure the accuracy of Input Tax Credit (ITC), and improve overall compliance with GST regulations. In this article, we’ll explore the new IMS, its functionality, and its impact on businesses.

What is the Invoice Management System (IMS)?

The Invoice Management System (IMS) is a new feature on the GST portal, designed to allow taxpayers to manage and take action on their invoices before filing their returns. As part of the system, recipients of goods and services can accept, reject, or keep pending invoices received from their suppliers. This provides businesses with better control and transparency over the Input Tax Credit (ITC) they can claim, as only the invoices that are accepted by the recipient will be considered for ITC in their GSTR-2B.

Key Features of the Invoice Management System

  • Real-time Invoice Management:

    • IMS allows businesses to track and manage their invoices in real-time. Once a supplier uploads an invoice in their GSTR-1, it becomes visible on the recipient’s IMS dashboard.
    • The recipient can take action by accepting, rejecting, or keeping the invoice pending. If no action is taken, the invoice is deemed accepted and automatically considered for ITC.
  • Streamlining Input Tax Credit (ITC) Claims:

    • IMS ensures that only accepted invoices are included in the GSTR-2B for claiming ITC. This reduces the chances of errors or discrepancies in tax filings.
    • Invoices that are kept pending will not be considered for ITC in the current filing period but can be processed in future periods, provided the statutory timelines are respected.
  • Amendment Handling:

    • If a supplier amends an invoice after it has been uploaded, the amendment is automatically reflected in the IMS dashboard. The recipient can review the changes and adjust their action (accept, reject, or pending) accordingly.
    • However, amended invoices filed through GSTR-1A will only reflect in the next month’s GSTR-2B, ensuring that the most updated information is always available.
  • Impact on GSTR-2B and GSTR-3B Filing:

    • The GSTR-2B (auto-drafted ITC statement) is generated on the 14th of every month, incorporating all accepted invoices up to that point. Recipients can continue to take action on invoices even after this date until they file their GSTR-3B (summary return).
    • After filing GSTR-3B, no further actions can be taken on that month’s invoices, ensuring that all accepted invoices are locked in for that tax period.
  • Sequential Filing System:

    • GSTR-2B generation is now sequential. The system will not generate GSTR-2B for the next return period until the previous period’s GSTR-3B is filed. This ensures continuity in ITC claim processes and prevents gaps in tax reporting.

How IMS Benefits Taxpayers

  • Better Control Over ITC: IMS empowers taxpayers to scrutinize the invoices uploaded by their suppliers, ensuring that only valid and accurate invoices are considered for ITC. This reduces the risk of errors or fraudulent claims and helps maintain compliance with GST rules.
  • Improved Communication between Buyers and Suppliers:
  • With IMS, recipients can quickly communicate their decision on invoices to their suppliers, who can then take corrective action if needed. This creates a more efficient and transparent supply chain.
  • Reduced Compliance Burden:
  • While IMS introduces new functionalities, it does not add any additional compliance burden. Invoices for which no action is taken are deemed accepted, simplifying the process for businesses that may not have the bandwidth to review every single invoice in detail.
  • Correction of Invoices:
  • If discrepancies are found in the invoices, the recipient can reject them and ask the supplier to correct and re-upload them. This ensures that businesses do not face ITC mismatches during their filings.

How IMS Works: A Step-by-Step Guide

 

    1. Supplier Uploads Invoice:

      • The supplier saves the invoice in GSTR-1 or IFF (Invoice Furnishing Facility). As soon as this happens, the invoice is reflected in the recipient’s IMS dashboard.
    2. Recipient Takes Action:

      • The recipient can choose to:
        • Accept: The invoice will be included in their GSTR-2B, and ITC can be claimed.
        • Reject: The invoice will not be included in GSTR-2B, and ITC cannot be claimed.
        • Keep Pending: The invoice will remain in the IMS dashboard for future action.
    3. Impact on GSTR-2B and GSTR-3B:

      • Based on the actions taken by the recipient, invoices will be included or excluded from GSTR-2B. Once GSTR-3B is filed, the invoices for that tax period are finalized.
    4. Amendments to Invoices:

      • If the supplier amends the invoice before filing GSTR-1, the amended version replaces the original invoice in the recipient’s IMS dashboard. However, if the amendment is made after the GSTR-1 is filed, it will only reflect in the next month’s GSTR-2B.

QRMP Taxpayers and IMS

  • For Quarterly Return, Monthly Payment (QRMP) taxpayers, the IMS follows a slightly different workflow:
  • Invoices uploaded via IFF by QRMP taxpayers will also flow into the IMS dashboard.
  • GSTR-2B for QRMP taxpayers will only be generated on a quarterly basis, as opposed to the monthly basis for regular taxpayers.

Important Deadlines and Provisions

  • Section 16(4) of the CGST Act: Taxpayers must ensure that they act on invoices within the prescribed timelines for ITC claims under Section 16(4).
  • Deemed Acceptance: If no action is taken on an invoice, it is automatically deemed accepted when GSTR-2B is generated.

Conclusion

The introduction of the Invoice Management System (IMS) is a significant development for taxpayers under GST. By allowing businesses to review, accept, or reject invoices in real-time, the system enhances the transparency of the ITC process and reduces the chances of errors in tax filings. For businesses, this new functionality not only simplifies invoice management but also ensures a smoother experience when claiming ITC. Adopting the IMS and staying compliant with GST regulations will ultimately benefit both taxpayers and the government by reducing disputes and ensuring timely and accurate tax collections.

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