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Shri. Sanjay Malhotra
Revenue Secretary
Ministry of Finance
North Block
New Delhi- 110001
Sub:Representation on the Invoice Management System (IMS) released by GSTN
Respected Sir,
The Bombay Chamber is India’s premier Chamber of Commerce and Industry situated in Mumbai, the industrial, financial and commercial capital of India. Established in 1836, it is the oldest Chamber in the country and has a long and illustrious history of 188 years of continuous service to trade and industry. It is registered under Section 8 of the Companies Act, 2013 (Section 25 of The Companies Act, 1956) a non-profit organization. With a large member base, the Chamber represents various industries in different sectors including SMEs.
The Goods and Services Tax Network (GSTN) has released an advisory dated September 3, 2024, on the GST Portal, introducing the new ‘Invoice Management System (IMS). According to the advisory, the system is designed to streamline the process of making changes to invoices directly through the GST portal, facilitating (recipient) taxpayers in matching their invoices with those issued by their suppliers for availing correct input tax credit (“ITC”).
As per the advisory, the recipient taxpayer will be able to accept, reject, mark as pending inward invoices or take no action against the said invoices in the IMS functionality. Basis the action taken, the GSTR-2B for the recipient will be generated to enable the filing of GSTR-3B. The advisory also outlines the operational workflow of the IMS on the GST Portal.
IMS is proposed to be operationalized w.e.f.1 October 2024 and will be accessible on the portal from November 2024.
IMS also calls for major alterations to the GST compliance workflow, business processes and current IT infrastructure of both the supplier and the recipient to enable them to comply with the new facility introduced by the GSTN. The workflow suggested in the IMS will be a significant shift from the way transactions are reviewed and compliances are currently undertaken under GST.
Members of the Chamber have raised several issues concerning IMS functionality which they may face once the IMS workflow is implemented from 1 October 2024. In the attached document, we have listed key issues of concern of the members and the respectful suggestions to address them and make the system more efficient.
As discussed in the attached representation document, implementation of the IMS, as it currently stands, is likely to have profound effect on taxpayers’ operations related to tax compliance, as well as notable commercial implications for businesses across various sectors. These changes could alter existing workflows and require substantial adjustments to compliance processes, potentially placing a strain on resources.
Thus, it would be prudent to engage more deeply with industry stakeholders to gather their insights and suggestions, ensuring a comprehensive understanding of the implications before moving forward with the introduction of the system. This collaborative approach would not only enhance the effectiveness of the IMS but also promote smoother adaptation for taxpayers.
Accordingly, it is humbly requested to defer the implementation of IMS functionality till the time a solution to various apprehensive scenarios is inbuilt in the system. Additionally, the industry may kindly be given at least 6 months’ time from the date when the law in relation to the said functionality is notified, in order to implement this new feature in their ERP or other accounting software for carrying out the compliance in an effective manner.
Bombay Chamber would be glad to facilitate the dialogue and assist both the government and taxpayers in effectively navigating these forthcoming changes.
We will be pleased to provide any further information that may be required for consideration and implementation of this representation.
Thanking you,
Yours sincerely,
Sandeep Khosla
Director General
