GSTR-2B and IMS: Important Advisory for QRMP and Non-Filers – November 2024 Update

GST Updates

Several taxpayers have reported that their GSTR-2B for October 2024 has not been generated on November 14th, 2024. It is important to understand that according to the design of the Input Service Management (IMS) system, GSTR-2B will not be generated under the following scenarios:

  1. Quarterly Return Monthly Payment (QRMP) Scheme:
    • Taxpayers who have opted for the QRMP scheme, meaning they are quarterly filers, will not have GSTR-2B generated for the first and second months of the quarter.
    • For instance, for the quarter from October to December 2024, the quarterly taxpayer will only receive the GSTR-2B for the period of December 2024, and not for October 2024 and November 2024.
  2. Non-filing of Previous Period GSTR-3B:
    • If a taxpayer has not filed their GSTR-3B for a previous period, the system will not generate the GSTR-2B for subsequent periods.
    • These taxpayers must file their pending GSTR-3B to enable the generation of GSTR-2B on demand.
    • For example, if a taxpayer has not filed the GSTR-3B for September 2024, their GSTR-2B for October 2024 will not be generated. Once they file the GSTR-3B for September 2024, they can generate the GSTR-2B for October 2024 by clicking the “Compute GSTR-2B (October 2024)” button on the IMS dashboard.

Understanding these scenarios helps in ensuring compliance and avoiding issues with the generation of GSTR-2B. Taxpayers are advised to keep track of their filing schedules and complete any pending returns promptly to avoid disruptions in their tax processes.

If you need further assistance or have specific queries, it is recommended to reach out to the GST Helpdesk or consult with a tax professional to ensure that all necessary steps are taken for a smooth compliance experience.

By staying informed and proactive, taxpayers can navigate the complexities of the IMS and GSTR-2B generation effectively, ensuring that their tax liabilities and credits are accurately reflected and managed.

IMS) for Taxpayers for simplifying GST ITC Claims and Reconciliation

The Invoice Management System (IMS) is now live and available to all taxpayers. This new system enables businesses to manage and match their invoices efficiently, ensuring that the correct Input Tax Credit (ITC) is availed. With IMS, taxpayers can accept, reject, or keep invoices pending for future action, streamlining the ITC claim process. The first GSTR-2B based on actions taken in IMS will be generated for the October 2024 return period, and will be available starting November 14, 2024. This enhanced functionality simplifies the reconciliation process, helping taxpayers stay compliant while optimizing their ITC claims.

Key FAQs about the Invoice Management System (IMS)

The IMS FAQs issued on October 17, 2024, provide valuable insights into how the system works, its scope, and what taxpayers need to know.

  1. Visibility of Invoices:
    Invoices eligible for the GSTR-2B of the October 2024 return period onwards will be available on the IMS dashboard. Any invoices from earlier return periods, such as September 2024 or prior, will not appear in the system.
  2. First GSTR-2B Generation Using IMS:
    The first draft of GSTR-2B based on actions taken in the IMS dashboard will be generated on November 14, 2024, for the October 2024 return period.
  3. Taking Action After GSTR-2B Generation:
    Taxpayers can continue to take action on invoices even after November 14, 2024, and recompute GSTR-2B for the October 2024 return period until the taxpayer files their GSTR-3B.
  4. Is It Mandatory to Act on IMS?:
    Acting on the IMS is optional. If no action is taken, the system will treat the records as accepted, and GSTR-2B will be generated automatically as per the current process.
  5. Rejecting Invoices or Debit Notes:
    Care should be taken when rejecting invoices or debit notes in IMS, as this action will prevent the taxpayer from claiming ITC for those invoices. Invoices should only be rejected if they do not pertain to the recipient or if the details are significantly erroneous.
  6. Reclaiming Erroneously Rejected ITC:
    If a taxpayer mistakenly rejects an invoice in IMS, they can accept it again before filing their GSTR-3B. After accepting the invoice, they should recompute their GSTR-2B to avail the ITC.
  7. Handling Credit Notes in IMS:
    Credit notes issued by suppliers can be accepted in IMS, even if the recipient has already reversed the corresponding ITC under rules such as Section 17(5) or Rule 42. If ITC has already been reversed, no additional reversal is required.
  8. Handling Amendments and Credit Notes:
  • Recipients cannot take action on amended invoices if the supplier has saved but not filed the amendment in GSTR-1. The recipient can only act after the supplier files the amendment.
  • Credit notes cannot be kept pending in IMS, as the supplier has already reduced their outward tax liability. Recipients can reject the credit note if it does not belong to them.
  1. Dealing with Credit Note Rejections:
    If a credit note is rejected by the recipient, the supplier’s liability will be increased in the subsequent GSTR-3B period, not in the same tax period in which the rejection occurs.

Benefits of the Invoice Management System (IMS)

  • Enhanced Invoice Reconciliation: The IMS provides a centralized platform for taxpayers to match their invoices with those issued by suppliers. This ensures that only valid ITC is claimed, reducing errors and discrepancies.
  • Streamlined ITC Management: Taxpayers can accept, reject, or keep invoices pending based on their review of supplier-provided data, allowing them to manage their ITC claims more effectively.
  • Real-time Actions: The system allows taxpayers to take real-time actions on their invoices, making it easier to ensure that all ITC claims are correct before filing GSTR-3B.
  • Flexibility: The ability to recompute GSTR-2B after the initial generation provides taxpayers with flexibility to make corrections or changes to their ITC claims up until the final submission of their returns.

Conclusion

The introduction of the Invoice Management System (IMS) marks a significant advancement in GST compliance. By providing taxpayers with the ability to actively manage their invoices and corresponding ITC claims, the system simplifies the process of reconciliation and helps to ensure the accuracy of the information submitted. With the first GSTR-2B based on IMS actions set to be generated in November 2024, taxpayers should familiarize themselves with the system and utilize its features to optimize their tax filings and compliance efforts.

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