Advisory: New Changes in Invoice Management System (IMS) Dated:
September 23rd, 2025
The Goods and Services
Tax Network (GSTN) has issued an advisory regarding significant new changes
in the Invoice Management System (IMS). These changes are aimed at
simplifying the taxation system, improving accuracy in Input Tax Credit (ITC)
reporting, and reducing the compliance burden on taxpayers.
Below is a detailed
summary of the key updates:
Pending
Action for Specified Records
Taxpayers are now
permitted to keep certain specified records pending for one tax period
only.
- For monthly taxpayers
– records can be kept pending for one month.
- For quarterly taxpayers
– records can be kept pending for one quarter.
Types of
records allowed to be kept pending:
a)
Credit Notes
– or upward amendment of credit notes.
b)
Downward amendment of credit notes
– where the original credit note was rejected.
c)
Downward amendment of Invoice/Debit
Note
– where the original invoice has already been accepted and GSTR-3B filed.
d)
ECO-Document downward amendment –
only where the original document has been accepted and GSTR-3B filed.
This change ensures
taxpayers have sufficient flexibility to manage mismatches and amendments
within the same tax cycle.
2.
Declaring ITC Reduction Amount
A major relief has been
introduced in cases of ITC reversal:
- If the recipient has not availed
ITC on the concerned invoice/document → no ITC reversal required.
- If the recipient has availed
partial ITC → reversal is required only to the extent of ITC
availed.
New IMS
Facility:
- Taxpayers can now declare the
exact ITC availed and the corresponding reversal amount.
- Reversal can be full or partial,
depending on actual availment.
- This facility can also be used where:
- The ITC was reversed earlier (fully
or partially).
- The ITC was never availed at all.
This provides clarity and
prevents unnecessary reversals, reducing taxpayer disputes and compliance
errors.
3. Option
to Save Remarks
Taxpayers will soon get
the option to save remarks while taking “Reject” or “Pending” action on
records.
- Remarks will be visible in GSTR-2B
for future reference.
- Suppliers can also view these remarks
in their Outward Supplies dashboard.
- This will help suppliers take
corrective action promptly and reduce mismatches.
4.
Important Dates
- The changes related to pending
action on credit notes and declaring ITC amounts will be effective
from the October 2025 tax period.
- The due date for keeping records
pending will be calculated based on the date/tax period in which such
documents were communicated by the supplier.
5.
Prospective Application
- These changes will be applicable only
to records filed by suppliers after the rollout in production.
- Taxpayers are advised to carefully
review these changes before finalizing returns and take timely action.
Conclusion
The new IMS updates
represent a taxpayer-friendly approach by GSTN.
- Flexibility in keeping specified
records pending.
- Clarity in ITC reversal obligations.
- Facility to declare exact ITC amounts
and add remarks for transparency.
Taxpayers should
familiarize themselves with these changes and ensure proper compliance starting
October 2025 to avoid mismatches and disputes.
Disclaimer: All the Information is based on the notification, circular advisory and order issued by the Govt. authority and judgement delivered by the court or the authority information is strictly for educational purposes and on the basis of our best understanding of laws & not binding on anyone.
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