The Goods and Services Tax Network (GSTN) has rolled out important changes in the Invoice Management System (IMS) to simplify GST compliance and reduce taxpayer burden. These updates will apply from the October 2025 tax period.
Below is a detailed breakdown of the changes, with practical examples for easy understanding:
1️⃣ Pending Action for Specified Records
Taxpayers can now keep certain records in pending status for one tax period only.
- Monthly filers: 1 month
- Quarterly filers: 1 quarter
Eligible Records
a. Credit Notes or upward amendments of Credit Notes
b. Downward amendment of CN where the original CN was rejected
c. Downward amendment of Invoice/Debit Note where the original Invoice is already accepted and GSTR-3B filed
d. E-Commerce Operator (ECO) document downward amendment where the original is accepted and GSTR-3B filed
💡 Example:
A supplier issues a credit note of ₹50,000 in October 2025, but the recipient is verifying stock details. The recipient can mark this credit note as Pending and take action in the November return (if monthly) or next quarter (if quarterly).
2️⃣ Declaring ITC Reduction Amount
GSTN clarifies that Input Tax Credit (ITC) needs to be reversed only if availed.
- If ITC never availed → No reversal.
- If ITC partially availed → Reverse only to the extent availed.
New IMS Facility
Taxpayers can now enter the actual ITC availed and specify the exact amount to be reversed—fully or partially.
💡 Example 1:
Invoice value ₹1,00,000 + GST ₹18,000.
Recipient availed ITC of only ₹9,000 earlier.
Supplier later issues a credit note reducing the taxable value.
👉 Recipient needs to reverse only ₹9,000, not the full ₹18,000.
💡 Example 2:
If no ITC was claimed on the invoice, no reversal is required even if a credit note is issued.
This prevents unnecessary reversals and over-compliance.
3️⃣ Option to Save Remarks
While rejecting or keeping a record pending, taxpayers can now add remarks (feature rolling out soon).
- Remarks will appear in GSTR-2B for the recipient and in the Outward Supplies dashboard for the supplier.
- Suppliers can use these remarks to correct invoices promptly.
💡 Example:
“Price mismatch – awaiting revised invoice” can be added as a remark.
The supplier immediately knows the reason for pending/rejection.
4️⃣ Important Dates
- Effective from: October 2025 tax period.
- Due date for keeping records pending: Based on the tax period when the supplier communicated the document.
- Applicability: Only for records filed after the production rollout of these changes.
✅ Compliance Tips
- Use the pending option wisely within the allowed month/quarter.
- Always declare the actual ITC availed to avoid penalties.
- Encourage suppliers to monitor remarks for faster resolution.
- Update ERP/accounting systems before the October 2025 filing cycle.
🏁 Conclusion
These updates—pending actions, flexible ITC declaration, and remark sharing—make the GST system more transparent and user-friendly. Businesses should familiarize themselves with the process to avoid last-minute filing errors once the changes go live.
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