Summary of New Changes in Invoice Management System (IMS)
(Effective from October Tax Period)
1. Pending Action for Specified Records
Taxpayers are now permitted to keep certain records pending for one tax period only:
• Monthly taxpayers – one month
• Quarterly taxpayers – one quarter
The records eligible for pending action include:
• Credit notes, or upward amendment of credit note
• Downward amendment of credit note (where original CN rejected)
• Downward amendment of invoice/debit note (where original invoice already accepted and GSTR-3B filed)
• ECO-document downward amendment (where original accepted and GSTR-3B filed)
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2. Declaring ITC Reduction Amount
• If ITC has not been availed, no reversal is needed.
• If ITC availed partially, reversal obligation is limited to that extent only.
A new IMS facility allows taxpayers to:
• Declare the actual ITC availed, and reverse it in full or part.
• Utilize this facility even if reversal was already made earlier.
• Apply this feature only to the specified records mentioned above.
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3. Option to Save Remarks
Taxpayers can now add and save remarks while rejecting or keeping records pending.
• Remarks will be visible in GSTR-2B for future reference.
• Remarks will also be available to suppliers in their Outward Supplies dashboard, enabling corrective actions.
• (Feature to be rolled out shortly).
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4. Important Dates & Prospective Application
• The facility for pending credit notes and ITC declaration will be effective from October tax period.
• The due date for keeping records pending will depend on the date/tax period of supplier communication.
• The changes will apply only prospectively, i.e., for records filed after production rollout.
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5. Advisory for Taxpayers
• Review the changes carefully before filing returns.
• Make use of the ITC declaration and remarks facility to reduce disputes and ensure transparency.
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These changes are expected to simplify compliance and bring more clarity in ITC reversal and record management under IMS.
