1. A new functionality will be introduced on GSTN portal w.e.f. 1 October 2024 which will require the recipient of goods or services to match the invoices/records with the details uploaded by supplier for availing ITC. In light of the same, recipient will have to either accept, reject or select the option as pending against each invoice appearing on the captioned dashboard. Consequently, the invoices that would appear in GSTR-2B shall become part of eligible ITC in the hands of the recipient. Read GSTN Advisory: New Invoice Management System (IMS) on GST Portal from Oct 2024
2. It is interesting to note that the captioned functionality is on the similar lines of the initial process of return filing introduced under GST i.e. GSTR-1, GSTR-2 and GSTR-3. While, one may have a question regarding the basis of introduction of said facility, the only argument would be advisory issued on GSTN portal.
3. The said facility will be available to recipient from the time of saving the records in GSTR-1/IFF/GSTR-1A by the supplier till the recipient files its GSTR-3B. In case the recipient does not take any action (i.e. accept, reject or pending) it will be considered as deemed acceptance and will move to GSTR-2B as an accepted invoice. Even the invoices reported or saved in GSTR-5 or GSTR-6 will be available in the dashboard. Further, even in case an action is taken by the recipient, the supplier can amend the details saved in its GSTR-1 and the amended invoice will replace the original invoice. In case invoice is amended through GSTR-1A, ITC corresponding to the same shall flow in GSTR-2B of recipient of the subsequent month.
4. In case where the action by recipient is marked as pending, ITC pertaining to the same can be availed as per the timeline prescribed under Section 16(4) of CGST Act.
5. While a draft GSTR-2B will be generated on 14th of subsequent month, if recipient has taken any action after 14th, he would be required to recompute their GSTR-2B. The said option will be available till the due date of filing of GSTR-3B of the said month.
6. Based on the actions taken by the recipient, invoices/records can be categorized as below:
a. No action taken: These are the invoices/records where no action has been taken by the recipient and therefore the same shall be deemed as accepted.
b. Accepted: These are the accepted invoices and shall form part of ‘ITC Available’ in GSTR-2B
c. Rejected: The rejected invoices will appear in ‘ITC rejected’ section ofGSTR-2B
d. Pending: Invoices will not captured in GSTR2B for the month and will be carried forward in IMS for further action in subsequent months. Pending action are not allowed in following scenarios;
i. Original credit note
ii. Upward amendment of the credit note irrespective of the action taken by recipient on the original credit note
iii. Downward amendment of the credit-note if original credit note was rejected by recipient,
iv. Downward amendment of Invoice/ Debit note where original Invoice/ Debit note was accepted by recipient and respective GSTR 3B has also been filed.
7. Following supplies will not go to IMS dashboard and will directly populated in GSTR3B
a. Inward RCM supplies where supplier has reported in the table 4B of IFF/GSTR1 or GSTR1A
b. Supplies where ITC is not eligible due to section 16(4) of CGST Act or on account of POS rule
8. It will be mandatory to take action on the original record/invoice uploaded by supplier before taking action on amended record in case where original and amended record/invoice belongs to 2 different GSTR-2B return period. If both the records belongs to same period’s GSTR-2B, only amended record will be considered for ITC calculation of GSTR-2B.
9. The liability of supplier will be increased in GSTR-3B of subsequent period for the invoices/records rejected by the recipient in IMS for following transactions:
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.
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Disclaimer: This article provides general information existing at the time of preparation and we take no responsibility to update it with the subsequent changes in the law. The article is intended as a news update and Affluence Advisory neither assumes nor accepts any responsibility for any loss arising to any person acting or refraining from acting as a result of any material contained in this article. It is recommended that professional advice be taken based on specific facts and circumstances. This article does not substitute the need to refer to the original pronouncement
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