Frequently Asked Questions (FAQ) on GST issued by CBEC

Invoice Management System (IMS)

 

Q 1. What is Invoice Management System (IMS)?

Ans. Invoice Management System (IMS) is a facility in GST system, where the invoices/records saved/filed by the supplier in GSTR-1/1A/IFF, can be accepted, rejected or kept pending by recipients in order to correctly avail ITC.

Q 2. How can I access IMS?

Ans. IMS can be accessed using below path on GST Portal : Dashboard > Services > Returns > Invoice Management System (IMS) Dashboard

Q 3. When will IMS be made available to taxpayers?

Ans. IMS will be launched on the GST Portal from 1st October 2024 and shall be available to the taxpayers for taking actions on the received invoices/records from 14th October 2024 onwards.

Q 4. What all records will be available in IMS for taking an action?

Ans. All the saved or filed original invoices/records and their amendments by suppliers through GSTR-1/1A/IFF will be available to the recipient for taking actions in IMS. However, the documents where ITC is not eligible either due to:

i. POS rule or

ii. Section 16(4) of the CGST Act,

will not appear on IMS and will directly go to ‘ITC Not Available’ section of GSTR-2B.

Q 5. What will happen to the accepted and rejected record?

Ans. All the accepted/rejected records belonging to a particular GSTR-2B period will be removed from IMS on filing of GSTR-3B for that particular period. Only the pending record and the invoices/records belongs to future tax period shall remain in IMS.

Q 6. When will the documents be flown to IMS?

Ans. The documents will be available in IMS as soon as they are saved by the supplier in their corresponding GSTR-1/1A/IFF.

Q 7. When can the recipient taxpayer take action on a record?

Ans. As soon as a supplier/ taxpayer saves an Invoice/ records in GSTR-1/1A/IFF, it is shown and is available to the recipient taxpayer in IMS for taking actions.

Q 8. What all documents will not be made available in IMS but will be part of GSTR-2B?

Ans. Below records will not be part of IMS but will directly flow to GSTR-2B:

1. Document flowing from the following forms:

• GSTR 5

• GSTR 6

2. ICEGATE documents

3. RCM records

4. Document where ITC is ineligible due to:

• POS rules

• Section 16(4) of CGST Act

5. Documents where ITC to be reversed on account of Rule 37A

Q 9. Who will have access to IMS functionality?

Ans. Taxpayers registered as normal taxpayers (including SEZ unit/Developer) and casual taxpayers will be able to access IMS functionality.

Q 10. What are the actions that I can take on an IMS ?

Ans. Below actions are allowed to take in IMS:

i. Accept

ii. Reject

iii. Pending

Note: By default all the records will flow into “No Action” category and records with “No Action” will be deemed accepted at the time of GSTR-2B generation.

Q 11. Are there any invoices/records where pending action is not allowed in IMS?

Ans. Yes, for the following 4 scnearios, pending action would not be available : -

A. Original Credit note rejected by the recipient

B. Upward amendment of the credit note rejected by the recipient irrespective of the action taken by recipient on the original credit note

C. Downward amendment of the credit note rejected by the recipient if original credit note was rejected by him,

D. Downward amendment of Invoice/ Debit note rejected by the recipient where original Invoice/Debit note was accepted by him and respective GSTR 3B has also been filed

Q 12. Can I take actions multiple time on a document?

Ans. Yes, action can be taken multiple times on an invoice/record before filling of GSTR 3B. In case of multiple actions on a record, latest action will overwrite the previous action. However, the action taken will be frozen at the time of filing the corresponding GSTR-3B by the recipient.

Q 13. What happens to the original record if the same record is amended by the supplier?

Ans. If original and amended record belongs to 2 different GSTR 2B return period, then it is mandatory to take action on original record and file the respective GSTR 3B before taking action on amended record (amended through GSTR-1/1A/IFF). In case if recipient take the action on amended record first then system will not allow to save the action in IMS.

In case both the original records and amended records belong to same period GSTR-2B, the action taken on amended records will prevail over the action taken on original record.

Q 14. What will happen to documents on which taxpayers has taken an action on IMS?

Ans. The documents will be treated in following manner based on different kind of action:

i. Accept –Accepted records will become part of ‘ITC Available’ section of respective GSTR 2B. ITC of accepted records will auto-populate in GSTR 3B.

ii. Reject –Rejected records will become part of ‘ITC Rejected’ section of respective GSTR 2B. ITC of rejected records will not auto-populate in GSTR 3B.

iii. Pending –Pending records will not become part of GSTR 2B and GSTR 3B. Such records will remain on IMS dashboard till the time same is accepted or rejected or till the time timeline prescribed in Section 16(4) of CGST Act.

iv. No Action - records with “No Action” status will be deemed accepted at the time of GSTR-2B generation.

Q 15. Which documents will be considered for GSTR-2B generation?

Ans. All the filed and accepted (no action will be treated as deemed accepted) or rejected records will be considered for GSTR-2B generation as per the cut-off dated of GSTR-2B. Saved records unless filed will be considered as “no action” committed and thus will flow as the status of the record that existed before saving for GSTR-2B generation.

Q 16. What If I have taken an action on a document in saved status but the same is edited/changed by the supplier before filing his GSTR-1?

Ans. In case a saved record is edited before filing of GSTR-1 by the supplier, the amended record will replace the saved document in IMS and the action taken on such record by the recipient will be reset. Thus, the edited record will be available for recipient for fresh action in IMS.

Similarly, if a document is deleted before filing of GSTR-1/1A/IFF by supplier then such document will be removed from IMS also.

Q 17. Will Reverse Charge document received from registered suppliers also form part of IMS ?

Ans. No, RCM invoices are not part of IMS but will continue to be part of GSTR-2B as it is being reflected today.

Q 18. As a taxpayer what all will I be able to view on the IMS?

Ans. The IMS has two different view:

i. Recipient view : As a recipient, a taxpayer will have an “inward supply” view to see all the specified documents which are saved or filed by your respective supplier. These documents will be available for actions by the recipient.

ii. Supplier view: As a supplier, a taxpayer will have an “Outward supply” view to see actions taken on all the specified documents by their respective recipient.

It will be made available shortly.

Q 19. What happens if recipient reject a record?

Ans. 1. If the recipient rejects the record before filling of GSTR 1 by supplier, then the invoice/record can be edited and supplier can file the GSTR 1 with same detail. This edited record will be made available in the IMS for action by the recipient.

2. If the recipient rejects after filling of GSTR 1 by supplier, then the supplier needs to amend/add the invoice/record in GSTR-1A or in subsequent GSTR 1/ IFF with same detail. Amended record will be made available in the IMS for action by the recipient.

Q 20. What will happen to the documents in IMS on filing of GSTR 3B by recipient?

Ans. All the accepted/rejected records belonging to a particular GSTR-2B period will be removed from IMS on filing of GSTR-3B for that particular period.

Q 21. What will happen to the documents kept pending in IMS?

Ans. Pending records will continue to be in IMS till the time of cut-off date as per section 16(4) of CGST Act, 2017.

Once records crossed the timeline prescribed in section 16(4) of CGST Act, it will be removed from IMS

Q 22. Can I download all the data available in IMS?

Ans. Yes, excel download facility is available to download the IMS data .

Q 23. What is draft GSTR 2B?

Ans. GSTR-2B will continue to be generated on 14th of every month with the same logic as current GSTR-2B which will now be considered as draft GSTR 2B. This draft will consist of all the accepted / deemed accepted records and rejected records. Here, rejected records are for view only and will not flow in GSTR-3B.

Q 24. Can I take any action after generation of draft GSTR 2B?

Ans. Yes, the recipient will be allowed to take an action on any record available in draft GSTR 2B also, till the filing of GSTR-3B. In such cases, at the time of filling GSTR-3B recipient will require to recompute his GSTR 2B to have impact of actions taken after 14th in his GSTR-3B.

Q 25. Is there any scenario where draft GSTR 2B will not be generated by system on 14th of subsequent month?

Ans. Yes, In case the previous period GSTR 3B is not filed by the taxpayer then the system will not generate their draft GSTR 2B on 14th of the subsequent month.

However, the taxpayer can generate their GSTR 2B from the IMS dashboard after filing their previous GSTR 3B

Q 26. How many times can I regenerate GSTR 2B?

Ans. Before filling of GSTR 3B, there is no restriction on number of times such GSTR-2B can be recomputed/regenerated.

Q 27. What about GSTR-2B for quarterly taxpayers?

Ans. For quarterly taxpayers, GSTR-2B will not be generated for the months M1 and M2 of the quarter. However, GSTR-2BQ for the quarter (M1, M2 and M3 combined) will be generated on 14th of Q+1 month and re-computation of 2B will be allowed on or after 14th of Q+1 month till filing of corresponding GSTR-3B. The same logic as is there for monthly GSTR-2B / 3B will be applicable.

Q 28. What will happen to GSTR-2A?

Ans. GSTR-2A shall continue to be generated as it is.

Q 29. Is it mandatory to re-compute GSTR 2B?

Ans. If there is any change made by recipient on IMS dashboard after draft GSTR 2B generation by system, it is mandatory to re-compute GSTR 2B.

Q 30. How to take an action on records available on IMS dashboard

Ans. 1. Action on Individual record: To take action on individual record, recipient can select the action by clicking on the radio button available at line-item level and then click on save button to save the action taken.

2. Action on multiple records: To take action on multiple records in one go, recipient can select multiple records or all the records through check-box option available on screen. After selecting multiple records, system will enable main action buttons on heading of action radio buttons with count of selected records. Through these action buttons recipient can take action on multiple records in one go.

Note: On all the multiple selected records, only one type of action can be taken.

Q 31. What will happen if the recipient rejects the Tax Invoice or Debit Note for the supplies of FY 23-24 which was eligible for GSTR 2B of Oct’24, given the deadline to avail the ITC by 30th November?

Ans. Taxpayer are advised to reconcile their records before filling of their GSTR 1 for October 2024 tax period for which due date is 11th November 2024.

The Taxpayer can accept/reject the record on IMS after due verification. The ITC for the rejected record will not flow to GSTR 2B for Oct’24.

However, recipient can change the action from rejected to accepted in IMS and recompute GSTR 2B at the time of filing gstr 3B and take corresponding ITC in the GSTR 3B for Oct’24.

Q 32. Can a supplier amend FCM invoice to RCM invoice and what will the impact on the ITC?

Ans. Yes, the supplier can amend an Invoice from FCM to RCM subject to the time limit as per GST law.

The system shall reduce the ITC of the amended FCM Invoice in case the said invoice was accepted by the recipient.

Further, the RCM invoice shall flow to GSTR 2B of the recipient.

Q 33. Can the place of supply be changed by the supplier in the GSTR 1 and what will be the impact on the ITC?

Ans. Yes, place of supply can be changed by the supplier in the GSTR 1 subject to the time limit given in the GST law.

Further if the ITC become ineligible due to change in place of supply, then recipient should reverse the ITC in the Table 4B1.

Q 34. What will happen if the recipient rejects the original Credit Note or upward amended Credit Note?

Ans. If the recipient rejects the Credit note and furnished the GSTR 3B then the corresponding liability will be added to the supplier liability in the GSTR 3B of subsequent tax period.

Q 35. Which invoices are visible on IMS dashboard since 14th Oct 2024?

Ans. IMS is launched from GSTR-2B return period of Oct’24. Hence, all the records eligible for GSTR2B of Oct’24 return period onwards will be made available on the IMS dashboard. All the invoices which are part of GSTR-2B of Sep’24 or older return periods will not be reflecting in IMS.

Q 36. Which is the first GSTR2B prepared using actions taken on IMS?

Ans. The first draft GSTR-2B on the basis of actions taken on invoices/records in the Invoice Management System dashboard would be generated and made available to all the taxpayers on 14th Nov 2024 for the return period Oct’24.

Q 37. Can taxpayer take action after 14th Nov,2024 and regenerate GSTR-2B of Oct’24 return period?

Ans. Taxpayer can take action on the invoices/records in their IMS dashboard and recompute their GSTR-2B of Oct 24’ return period even after 14th November 2024 till the time the taxpayer files his GSTR-3B.

Q 38. Is it mandatory to act on IMS? What happens if no action is taken?

Ans. It is not mandatory to act on records in IMS dashboard for GSTR2B generation. The records where no action is taken by the recipient would be treated as accepted by the system and a GSTR-2B would be generated as it is generated presently.

Q 39. When should an invoice/debit note be rejected?

Ans. Rejection of an invoice/debit note should be done very carefully as rejection will result in no ITC for the recipient.

A record may be rejected if it does not pertain to the recipient, or the detail of the record is erroneous to such an extent that CN and DN cannot handle the situation.

Q 40. In light of the time limit to avail ITC being till 30th November for FY 2023-24 or furnishing of annual return whichever is earlier, how can the ITC of erroneously rejected invoice in IMS, be taken by the recipient in the FY 2023-24?

Ans. In case the recipient taxpayer erroneously rejects an invoice in IMS, then the same invoice can be accepted in IMS again before filing of GSTR-3B.

After accepting the said invoice, the recipient taxpayer should recompute the updated GSTR-2B for availing the credit in GSTR 3B for the FY 2023-24.

Q 41. How can recipient accept a genuine credit note issued by supplier in IMS as it will result further reduction of the recipient ITC, however recipient had reversed ITC corresponding to invoice itself because of 17(5), Rule 42, 38, 43 etc., or not availed the ITC at all because of POS or 16(4) etc., ineligibility?

Ans. In such cases recipient can accept the said credit note in IMS. As recipient had already reversed the ITC, there is no need for reversal of ITC again in case of such credit note.

Q 42. What action shall be available on upward amended invoice/debit notes, where the upward amended invoice/debit notes is Saved by supplier and the same is not filed?

Ans. The recipient will not be able to take an action on an upward amended invoice/debit notes, if the said amended record has only been saved by supplier in GSTR-1/GSTR-1A/IFF but the same record has not been filed.

The recipient will be able to take action once the supplier files such record.

Q 43. What to do in case wrong invoice is corrected by issuance of Credit Note by the supplier instead of amending the same and such Credit note has been rejected by the recipient?

Ans. In the absence of linkage of Credit Note with the corresponding invoices, system cannot understand whether original invoice for this Credit Note was accepted or rejected.

Therefore, if the invoice is not correct, then it is advisable to rectify the mistake through amendment of invoices in the GSTR 1 instead of issuance of a Credit Note.

Q 44. Can the Credit Note be kept as pending in IMS? If no, then why?

Ans. Credit Note cannot be kept pending in the IMS by the recipient as the supplier has reduced its outward tax liability at the time of issuance of credit note.

IMS does not change the existing flow where the documents/records reported by the supplier in the GSTR 1 is accepted and corresponding impact is reflected in the GSTR 2B. Now because of IMS, an additional option has been provided to recipient to reject the credit note if it does not belong to him.

Q 45. Whether liability can be added in the same GSTR 3B in case where credit note has been rejected by the recipient before filing of GSTR 3B by the supplier?

Ans. No, if a credit note is rejected by the recipient, the liability of the supplier is increased on the portal to that extent in the GSTR 3B of subsequent tax period and not in the GSTR 3B of same tax period.

Q 46. How can a recipient avail ITC of wrongly rejected Invoices/ Debit notes/ECO-Documents in IMS as corresponding GSTR-3B of same tax period was also filed by recipient?

Ans. In such cases recipient can request to the corresponding supplier to report the same record (without any change) in same return period’s GSTR-1A or respective amendment table of subsequent GSTR-1/IFF. Thus, recipient can avail the ITC basis on amended record by accepting such record on IMS and recomputing GSTR-2B on IMS. Here the recipient will get ITC of complete amended value as original record was rejected by the recipient.

However, recipient will be able to take ITC for the again furnished document by the supplier, as stated above, only in the GSTR-2B of the concerned tax-period.

Q 47. If any original record is rejected by the recipient and supplier furnishes the same record in GSTR-1A of same tax period or in the amendment table of GSTR-1/IFF of subsequent period, till the specified time limit, then what impact it will have on supplier’s liability?

Ans. In case supplier had furnished an original record in GSTR-1/IFF but the same record was rejected wrongly by the recipient in IMS. In such cases supplier on noticing the same in the supplier’s view of IMS dashboard or on request of recipient, may furnish the same record again (without any change) in GSTR-1A of same tax period or in the amendment table of GSTR-1/IFF in any subsequent period, till the specified time limit, then the liability of supplier will not increase. As amendment table take delta value only. Thus, in present case of same values, differential liability increase will be zero.

Q 48. As a recipient taxpayer, how to reverse ITC of wrongly rejected Credit note in IMS as the corresponding GSTR-3B has already been filed?

Ans. In such cases recipient can request the concerned supplier to furnish the same Credit note (CN) without any change in the same return period’s GSTR-1A or in amendment table of subsequent period’s GSTR-1/IFF. Now recipient can reverse the availed ITC based on the amended CN by accepting the CN on IMS. Hence, the recipient’s ITC will get reduced with complete amended value, as soon as the recipient recomputes GSTR-2B on IMS. The reduced value is same as that of the value of original CN as in this case the complete original CN was rejected by the recipient.

Q 49. If any original Credit note was rejected by the recipient and supplier furnishes the same credit note in GSTR-1A of same tax period or in the amendment table of GSTR-1/IFF of any future tax-period, till the specified time limit, then what impact it will have on supplier’s liability?

Ans. At first instant the supplier’s liability will be added back in the open GSTR-3B return, because of original credit note rejection by the recipient. However, as the supplier furnishes the same credit note in GSTR-1A of same tax period or in amendment table of GSTR-1/IFF in any subsequent period, supplier’s liability for this amendment will get reduced again corresponding to the value of amended CN (which in this case is same as original). Thus, net effect on liability of supplier will be only once.