GSTN issues advisory on the changes introduced in the Invoice Management System

 This Tax Alert summarizes the recent advisory ^[1] issued by Goods and Services Tax Network (GSTN) on the changes introduced in the Invoice Management System (IMS).

The highlights of the advisory are:

• Taxpayers can keep the following records pending for a limited period of one tax period i.e., one month for monthly taxpayers and one quarter for quarterly taxpayers:
  
  
  
• Credit notes, or upward amendment of credit notes.
• Downward amendment of credit notes where original credit note was rejected.
• Downward amendment of invoice / debit note where original invoice was accepted and GSTR-3B was filed.
• Downward amendment of documents issued by e-commerce operator where original document was accepted, and GSTR 3B was filed.
  
  The due date for keeping records pending will be calculated based on the date/ tax period in which such documents have been communicated by the supplier.
  
  

• No reversal of input tax credit (ITC) is required if the recipient has not availed ITC on the relevant invoice. In cases where ITC has been availed partially, the obligation to reverse ITC is limited to the amount actually availed.
  
  
  
• Accordingly, a new facility has been introduced in IMS allowing taxpayers to declare the actual amount of ITC availed and specify the reversal amount required, either in full or in part, for selected records. This feature can be used when reversal has already been made previously or ITC was never claimed on the relevant invoice or document.
  
  
  
• An option is also made available to the taxpayers to save remarks while marking records as rejected or pending. These remarks will be visible to the recipient in GSTR-2B for future reference and to suppliers via their outward supplies dashboard, facilitating corrective action.
  
  
  
• The changes, including the facility to keep credit notes pending and declaration of ITC amounts, will be effective from October 2025 tax period and shall apply prospectively to records filed by suppliers after the rollout of the changes.

Comments:

• Allowing taxpayers a defined timeframe to take action on specified records enhances their ability to make informed choices regarding acceptance or rejection, ensuring more deliberate and compliant decision-making.
  
  
  
• Businesses may need to closely assess potential ERP system updates and modifications arising from the new IMS requirements.

^[1] Advisory dated 23 September 2025