Invoice Management System - The Potential Issues That Could Arise - It Is An Update, Nobody Asked For
The GST Authorities have issued an Advisory which seeks to implement the Invoice Management System (IMS) from 1st October 2024, wherein it is stated that the Assessee's will have the option to accept, reject, or keep pending, the invoices reported by their suppliers through an IMS Dashboard.
Further, it states that if the Assessee has not taken any action, it will be deemed that the assessee has accepted the invoices so uploaded by their suppliers
Questions To Ponder Upon:
๐ Why do we need an accept, reject, or pending system in connection with invoices in GSTR 1 when we already have a GSTR 1A in place, which provides for making amendments in case there is a mistake in GSTR-1.
๐ What is the Department trying to achieve by putting the onus on the receiver of supply to accept, reject invoices.
๐ Can this potentially lead to a situation wherein the supplier makes a mistake, and the receiver is denied benefit or is penalized at a later stage stating that no action was taken by such receiver and therefore there was a deemed acceptance, and having accepted the invoice, the receiver cannot come and dispute the anomaly in the invoice
Example:
Assuming my supplier has raised an invoice for Rs.1,00,000/- which ought to have been Rs.90,000/-. For whatever reasons I missed taking any action on the invoice and it is now deemed to have been accepted.
Later I tell my supplier that a credit note ought to be issued for Rs.10,000. Upon issuance of such credit note I as the supply receiver ought to reverse credit proportionately.
Now can the Department say, that I accepted the invoice earlier and now that I am reversing ITC on account of a credit note, I am liable to reverse the same along with interest on account of not rejecting or keeping the invoice pending at the time it was uploaded.
What is mentioned above is only an example and there could be numerous other issues wherein benefits are denied or supply receiver is penalized for having accepted or deemed accepted the invoice at the time it was uploaded.
Shifting the onus on the service receiver could therefore do more harm than making it easier for them. Again this may or may not happen.
The crux of the matter here is that the GST Authorities have suddenly decided to put the onus on the supply receiver for no justified reason through a system that does not exhibit any major benefit through its implementation.
The real problem businesses are facing is the non-uploading of invoices by suppliers and not the invoices that have been uploaded, as such invoice reflects in GSTR-2B and there are enough options to correct mistakes in such invoices.
Why then implement another layer of checking by placing the onus on the supply receiver through IMS.
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