Recent GST Advisories on Portal Updates and Compliance

In November 2024, GSTN released several advisories to update taxpayers on various compliance requirements and functionalities on the GST portal. Key advisories include a reduction in the threshold for reporting e-invoices on the IRP portal, from Rs. 100 crore to Rs. 10 crore AATO, effective from April 1, 2025. Additionally, a new Form GST DRC-03A was introduced to link payments made through DRC-03 with corresponding demand orders. The advisory on the waiver scheme under Section 128A provides relief from interest and penalties for tax disputes in specific cases, with a deadline to pay taxes by March 31, 2025, for waiver benefits. Further, the Invoice Management System (IMS), which allows recipients to manage invoices from suppliers, has faced initial challenges in its implementation. The system may incorrectly populate ITC and tax liabilities in GSTR-3B due to errors in actions taken by recipients, though these can be amended before filing. Moreover, the Supplier View in IMS allows suppliers to track actions taken on their invoices by recipients. Lastly, GSTN addressed reporting challenges for TDS on scrap dealers, noting that taxpayers who received registration in November 2024 could still report TDS deducted in October 2024. These advisories aim to streamline GST compliance processes and assist taxpayers in adapting to the evolving system.

Common portal of GST, GSTN keeps on issuing advisories on new functions / updates on the portal for upgradation of functionalities and new options or functions enabled for implementation by taxpayers.

During the month of November 2024, the following advisories have been issued so far in relation to the various compliances by GSTN:

•  Time Limit for Reporting e-Invoice on the IRP Portal
• Advisory for Form GST DRC-03A
• Advisory for waiver scheme under Section 128A
• Advisory regarding IMS during initial phase of its implementation
• Advisory on Invoice Management System (IMS)
• Advisory on IMS on Supplier View
• Advisory on GSTR -2B and IMS
• Advisory for Reporting TDS reporting for Scrap Dealers

These are summarized below:

 Time Limit for Reporting e-Invoice on the IRP Portal

• GSTN has issued an advisory on time limit for reporting e-invoices on the IRP Portal for taxpayers with Rs. 10 crore or above of Average Aggregate Turnover (AATO).
• Further to earlier advisory dated 13.09.2023, where time limit of 30 days for reporting e-invoice on IRP portal for taxpayers with AATO of Rs. 100 crore or above was notified, GSTN has now advised lowering of threshold limit from Rs. 100 crore to Rs. 10 crore.
• From 1st April 2025, taxpayers with an AATO of 10 crores and above would not be allowed to report e-Invoices older than 30 days from the date of reporting on IRP portals.
• This restriction would apply to all document types (Invoices/Credit Notes/Debit Notes) for which an IRN is to be generated.
• There would however, be no such reporting restriction on taxpayers with an AATO of less than 10 crores as of now.
• The above limit would come into effect from 1st April, 2025 onwards.

 (Source: GSTN Advisory dated 05.11.2024)

Advisory for Form GST DRC-03A

• The GSTN has issued an update dated 05.11.2024 to inform that it has developed the new Form GST DRC-03A on the GST portal which is available now to adjust the paid amount through DRC-03 against the corresponding demand order.
• Therefore, it has been advised to the taxpayers to use the DRC-03A form to link the payment made via DRC-03 with the demand order.

(Source: GSTN Advisory dated 05.11.2024)

 GSTN Advisory for waiver scheme under Section 128A

• GSTN has issued an advisory for waiver scheme under Section 128A for reducing the tax disputes and to provide a relief to the taxpayers for waiver of interest and penalties in the demand notices or orders issued under Section 73 of the CGST Act, 2017 (i.e. the cases not involving fraud, suppression or wilful misstatement, etc.) for the Financial years 2017-18, 2018-19 and 2019-20.
• Rule 164 of CGST Rules, 2017 has been notified vide Notification No. 20/2024 dated. 8th October 2024, effective from 1st November, 2024 which provides procedural guidelines for the said waiver scheme.
• GSTN has advised that Form GST SPL-01 and Form GST SPL-02 are under development and same will be made available on the common portal, tentatively from the first week of January, 2025.
• Taxpayers have been advised to pay the tax amount demanded in the notice, statement, or order issued under Section 73 on or before March 31st, 2025, to ensure that they receive the waiver benefits by paying their taxes before the deadline.
• Taxpayer can pay the demanded tax amount through the “payment towards demand” facility in case of demand orders and through Form GST DRC-03 in case of notices.
• If payment has already been done through Form GST DRC-03 for any demand order, then taxpayer need to link the said Form GST DRC 03 with such demand order through Form GST DRC-03A, which is now available on the common portal.

 (Source: GSTN Advisory dated 08.11.2024)

GSTN advisory regarding IMS during initial phase of its implementation

• Invoice Management System (IMS) is an optional facility introduced from October 2024 on GST Portal, on which the invoices/records saved/furnished by the supplier in GSTR-1/1A/IFF, can be accepted, rejected or kept pending by recipients .Based on the action taken by the recipient on the IMS, system will generate the GSTR 2B of the recipient on 14th of subsequent month.
• The Taxpayer can accept/reject/keep pending the invoice/record on IMS after due verification from his accounts. The ITC for the rejected record will not be available to the recipient in the GSTR 2B . Further, the liability and input tax credit is being auto -populated in GSTR 3B of the taxpayer on the portal based on his liability declared in GSTR 1/1A and input tax credit made available in his GSTR 2B. However, the taxpayer can presently edit the said auto-populated details in GSTR 3B before filing the same.
• IMS, being a new functionality introduced on the portal, there may be cases where in the initial phase of implementation of IMS, the recipient may make error/mistake while taking action (like acceptance/rejection/keeping pending) on the IMS in respect of an invoice/record. As GSTR-2B of the recipient will be generated on the portal based on the actions taken by the recipient on the IMS, any mistake in the action taken by the recipient on the IMS could result in incorrect details of available/eligible input tax credit to the recipient being shown in his GSTR-2B, which will also be auto-populated in his GSTR-3B on the portal. In such cases, the recipient can change the action on the IMS in respect of an invoice/record ( e.g. from rejected to accepted or vice versa) and can recompute his GSTR-2B at any time till the filing of GSTR-3B for the corresponding tax period, so that correct ITC is auto-populated in his GSTR-3B.
• Despite this, there may still be some cases, where the recipient is not able to correct the action taken on the IMS, resulting in wrong auto-population of ITC in GSTR-3B of the recipient or wrong auto-population of liability in GSTR-3B of the corresponding supplier. Therefore, during this initial phase of implementation of IMS, the taxpayers are advised that in such cases, where due to any inadvertent mistake in the action taken on the IMS, if incorrect details of ITC/ liability are auto-populated in GSTR-3B on the portal, the taxpayer may before filing their GSTR-3B return, edit such wrongly populated ITC/liability in their GSTR-3B, to correctly avail ITC or pay correct tax liability based on the factual position as per the documents/records available with him.

(Source: GSTN Advisory dated 12.11.2024)

 GSTN Advisory on Invoice Management System (IMS)

• GSTN has issued an advisory regarding IMS during initial phase of its implementation.
• GSTN recongnises that :
• IMS, being a new functionality introduced on the portal, there may be cases where in the initial phase of implementation of IMS, the recipient may make error/mistake while taking action (like acceptance/rejection/keeping pending) on the IMS in respect of an invoice/record.
• As GSTR-2B of the recipient will be generated on the portal based on the actions taken by the recipient on the IMS, any mistake in the action taken by the recipient on the IMS could result in incorrect details of available/eligible input tax credit to the recipient being shown in his GSTR-2B, which will also be auto-populated in his GSTR-3B on the portal.
• In such cases, the recipient can change the action on the IMS in respect of an invoice/record (e.g. from rejected to accepted or vice versa) and can recompute his GSTR-2B at any time till the filing of GSTR-3B for the corresponding tax period, so that correct ITC is auto-populated in his GSTR-3B.
• However, there may still be some cases, where the recipient is not able to correct the action taken on the IMS, resulting in wrong auto-population of ITC in GSTR-3B of the recipient or wrong auto-population of liability in GSTR-3B of the corresponding supplier.
• Thus, during this initial phase of implementation of IMS, the taxpayers are advised that in such cases, where due to any inadvertent mistake in the action taken on the IMS, if incorrect details of ITC/ liability are auto-populated in GSTR-3B on the portal, the taxpayer may before filing their GSTR-3B return, edit such wrongly populated ITC/liability in their GSTR-3B, to correctly avail ITC or pay correct tax liability based on the factual position as per the documents/records available with him.

(Source: GSTN Advisory dated 12.11.2024)

GSTN Advisory on IMS on Supplier View

• Invoice Management System (IMS) was made available on the GST Portal from 14th October, 2024 wherein the recipient taxpayer can accept, reject or keep the invoices pending which are saved/filed by their suppliers in their respective GSTR-1/1A/IFF.
• The Supplier Viewof IMS has also now been made available where the action taken by their recipients on the records/invoices reported in GSTR-1/1A/IFF, will be visible to the suppliers in ‘Supplier View’ functionality. This will help a supplier taxpayer to see the action taken on their reported outwards supplies and will help to avoid any wrong action taken by the recipient taxpayer.
• It may be noted that the following records/invoices are not available in IMS for taking any kind of actions by the recipient but are visible in supplier view with the status as ‘No Action Taken’:
• Documents where ITC is not eligible either due to Place of Supply (POS) rule or Section 16(4) of the CGST Act,
• Records attracting Reverse Charge Mechanism (RCM) Supplies
• Further, any action taken on records can be changed by the recipient taxpayer till the filing of GSTR-3B of the return period. In case the taxpayer changes any action after the generation of GSTR-2B, they need to click the GSTR-2B re-compute button to re-compute their GSTR-2B based on the new actions taken.

(Source: GSTN Advisory dated 13.11.2024)

GSTN Advisory on GSTR -2B and IMS

GSTN has advised that as per the design of IMS, GSTR-2B will not be generated by the system in below scenarios:

• (i) In case the taxpayer has opted for QRMP scheme (Quarterly filers), GSTR-2B will not be generated for first and second month of the quarter. Ex. For quarter Oct-Dec, 2024, the quarterly taxpayer will get GSTR-2B for December-2024 period only and not for October-2024 & November-2024.
• In case the taxpayer has not filed their previous period GSTR-3B, GSTR-2B will not be generated by the system. Such taxpayers need to file their pending GSTR-3B in order to generate GSTR-2B on demand.

For example, if the taxpayer has not filed GSTR-3B for September-2024, their GSTR-2B for October-2024 will not be generated. Once the taxpayer files their GSTR-3B for September-2024, they will be able to generate their GSTR-2B for October-2024 by clicking the “Compute GSTR-2B (OCT 2024)” button on the IMS dashboard.

(Source: GSTN Advisory dated 16.11.2024)

GSTN Advisory for Reporting TDS reporting for Scrap Dealers

• GSTN has issued an advisory for reporting TDS deducted by Scrap Dealers in October 2024.
• As per Notification No. 25/2024-Central Tax, w.e.f. 10.10.2024, any registered person receiving supplies of metal scrap classified under Chapters 72 to 81 of the First Schedule to the Customs Tariff Act, 1975 (51 of 1975), from another registered person, is required to deduct TDS under Section 51 of the CGST Act, 2017.
• Many taxpayers were not able to file return for October, 2024 because while the taxpayers applied for GST registration in October 2024 pursuant to the above notification, their GST registrations were approved only in November 2024. Hence, in the return dropdown the month October 2024 is not visible to such taxpayers. This is as per the existing GSTN system design where returns for tax period prior to registration month is not enabled for taxpayers.
• For taxpayers who were granted registration in November 2024, but deducted TDS in October 2024, GSTN has advised to report the consolidated amount of TDS deducted for the period from 10.10.2024 to 30.11.2024 in the GSTR-7 return to be filed for the month November 2024.

(Source: GSTN Advisory dated 27.11.2024)