Summary: In September 2024, GSTN issued several advisories on important updates for taxpayers. Key advisories include the reopening of Input Tax Credit (ITC) reversal reporting, allowing taxpayers to reclaim previously reversed ITC before deadlines in October and November. The Draft Manual on the new Invoice Management System (IMS) details how taxpayers can manage invoice corrections and track ITC. GST return data older than seven years is being archived, and the first set of data from July 2017 has already been removed. Notices and orders issued through the GST portal may no longer require digital signatures, as they are digitally logged by officers. Finally, the GST return data archival process has been temporarily paused following feedback, but will resume after further notice. Taxpayers are advised to download necessary data for future reference.
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 September, 2024, the following advisories have been issued so far in relation to the various compliances by GSTN:
- Advisory on Reopening of ITC Reversal Opening Balance
- Draft Manual on Invoice Management System
- Archival of GST Returns data on GST portal
- Issuance of Notices / Orders without Digital Signatures of the issuing Authorities
- Restoration of GST Returns Data on Portal
These are summarized below:
Advisory on Reopening of ITC Reversal Opening Balance
- GSTN has issued an Advisory on Re-opening of Reporting ITC Reversal Opening Balance.
- The re-claimable ITC earlier reversed in Table 4(B)2 of Form GSTR-3B may be subsequently claimed in Table 4(A)5 on fulfilment of necessary conditions and such reclaimed ITC also needs to be reported in Table 4D(1).
- For correct and accurate reporting of ITC reversal and reclaim thereof and to avoid clerical mistakes, a new ledger i.e., Electronic Credit Reversal and Re-claimed Statement was introduced on the GST portal from August 2023 return period for monthly taxpayers and from July-September 2023 quarter for quarterly taxpayers. An opportunity to report their cumulative ITC reversal as an opening balance in the newly introduced Electronic Credit Reversal and Re-claimed Statement was also given.
- GSTN has now provided one final opportunity to report their cumulative ITC reversal (ITC that has been reversed earlier and has not yet been reclaimed) as opening balance for “Electronic Credit Reversal and Re-claimed Statement”, if any, before hard locking the reversal and reclaim ledger.
- The important dates to report opening balance are as follows:
- The functionality to reporting the opening balance will be available from 15th September 2024 to 31st October 2024.
- The amendments in declared opening balance will be available till 30th November, 2024.
- Taxpayers having monthly filing frequency are required to report their opening balance considering the ITC reversal done till the return period of July 2023 only. As after this period balance is already available in ledger.
- Quarterly taxpayers shall report their opening balance up to Q1 of the financial year 2023-24, considering the ITC reversal made till the April-June 2023 return period only. As after this period balance is already available in ledger.
- After such dates, system would not allow to re-claim of ITC in excess of the amount reversed earlier and the taxpayers will not be able to reclaim excess ITC compared to the balance available in their Electronic Credit Reversal and Re-claimed Statement.
(Source: GSTN Advisory Dated 17/09/2024)
Draft Manual on Invoice Management System
- The GSTN has issued an update to inform that a new communication process called the Invoice Management System (IMS) is being brought up at portal to enable taxpayers to efficiently address invoice corrections/amendments with their suppliers through the portal.
- This will also facilitate taxpayer in matching of their records/invoices vis a vis issued by their suppliers for availing the correct Input Tax Credit (ITC) and shall allow the recipient taxpayers to either accept or reject an invoice or to keep it pending in the system, which can be availed later. This facility shall be available to the taxpayer from 1st October onwards on the GST portal.
- Team GSTIN has recently issued 34 FAQ’s on Invoice Management System (IMS) for better understanding. We are attaching herewith the same for your reference.
(Source: GSTN Advisory Dated 17/09/2024)
Archival of GST Returns data on GST portal
- Section 39 (11) of the CGST Act, 2017 , implemented w.e.f 01-10-2023 vide Notification No. 28/2023 – Central Tax dated 31th July, 2023, provides that the taxpayers shall not be allowed file their GST returns after the expiry of a period of three years from the due date of furnishing the said return.
- As per the data policy, GST return data for viewing by taxpayers is to be retained at the portal only for 7 years as implemented w.e.f. 01.10.2023. Thus, GSTN has decided that the return data will not be available to view beyond 7 years for taxpayers.
- Accordingly, on 01st August 2024 return filed for July 2017 has been archived and on 01st September 2024, data for August 2017 has been archived. Further, this data archival is going to be a monthly activity hence on 01st October, 2024 data of September 2017 shall be taken down from the GST portal and so on so forth.
- Hence, the taxpayers have been advised to download their relevant data from the GST portal for any future reference, if required.
- This has, however, been restored w.e.f. 29.09.2024, for the time being.
(Source: GSTN Advisory dated 24.09.2024 and 29.09.2024)
Issuance of Notices / Orders without Digital Signatures of the issuing Authorities
- The GSTN has issued an Advisory regarding the validity of documents issued by the tax officers on the common portal viz. SCN / Assessment Orders / Refund Orders etc. without the digital signatures on the pdf document downloaded from the common portal.
- It is advised that such documents are generated on the common portal from the login of the officer, who logs in through Digital Signatures.
- These documents being computer generated on the command of the officer, may not require physical signatures of the officer as these documents can be issued by the officer only after logging into the common portal using Digital Signature.
- All these documents in JSON format containing the order details along with the issuing officer details are stored in the GST system with the digital signature of the issuing officer.
- The validity of the document in question vis-à-vis who and for what purpose these documents have been issued can also be verified by the taxpayer pre-login as well as after login from the GST common portal by navigating to the path: https://www.gst.gov.in–>Dashboard–>Services–>User Services–>Verify RFN.
(Source: GSTN Advisory dated 25.09.2024)
Restoration of GST Returns Data on Portal
- GSTN has decided to restore the archival process of GST returns data, as advised by Advisory dated 24.09.2024.
- GST has now advised that in view of the requests received from the trade due to the difficulties faced, data has been restored back on the portal.
- It has also been recommended to download and save the data if needed, as the archival policy shall be implemented again after giving advance information.
(Source: GSTN Advisory dated 29.09.2024)
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