The Invoice Management System (IMS) has brought greater structure to GST compliance, but it has also raised many practical, operational questions. Most of these questions are not about legal interpretation. They are about how the system behaves in real-life situations and how taxpayer actions are viewed during audits.
This article answers the most frequently asked IMS questions, based on real scenarios faced during monthly closings, internal audits, departmental verifications, and advisory reviews. The goal is not academic completeness, but operational certainty.
Why Practical FAQs Are Essential Under IMS
IMS records decisions, not just data. Every action, or inaction, has consequences. Many GST challenges today arise because:
- Users misunderstand what acceptance actually means
- Pending invoices are treated casually
- Silence is mistaken for safety
- System behaviour is underestimated during audits
Clear answers to practical questions help prevent avoidable ITC loss, audit objections, and governance gaps.
FAQs on Invoice Acceptance Under IMS
Does accepting an invoice mean ITC must be claimed immediately?
No. Acceptance only confirms that the invoice is valid and eligible. ITC can still be deferred based on internal policy or cash-flow considerations, as long as statutory timelines are respected.
Practical insight: Repeated acceptance without claiming ITC may raise audit questions. Clear internal documentation is advisable.
Can an accepted invoice be reversed later?
Once GSTR-3B is filed, IMS actions are locked. Any reversal must be done through statutory reversal mechanisms, not by changing IMS status.
Key takeaway: IMS decisions become legally final after filing.
Is “deemed acceptance” risky?
Yes. Deemed acceptance has the same legal consequence as conscious acceptance. Lack of action is not a defence.
Important learning: Under IMS, silence is treated as approval.
FAQs on Pending Invoices
How long can an invoice remain pending?
There is no system-imposed limit, but statutory ITC timelines still apply. Pending invoices risk permanent ITC loss if not resolved in time.
Can pending invoices be partially accepted later?
No. IMS operates at the document level, not value level. Partial acceptance is not permitted.
Is keeping invoices pending safer than rejecting them?
Not necessarily. Excessive or prolonged pending is often viewed as weak governance, not prudence.
Audit perspective: Pending status must be actively managed and justified.
FAQs on Invoice Rejection
Does rejection affect supplier liability?
Yes, in certain cases, such as credit notes or amendments. Rejections are visible to the system and may impact the supplier’s tax position.
Can a wrongly rejected invoice be corrected?
Correction requires supplier re-reporting or amendment. The recipient cannot unilaterally undo a rejection after filing.
Should commercial disputes result in rejection?
No. Rejection must be tax-driven, not commercial. Commercial disputes should be handled outside IMS unless they affect tax validity.
FAQs on Supplier Amendments
If a supplier amends an invoice after acceptance, is re-acceptance required?
Yes. Amended documents require fresh review. Prior acceptance does not automatically carry forward.
Can suppliers amend invoices repeatedly?
Systemically, yes, but repeated amendments trigger scrutiny. Recipients should track amendment frequency carefully.
FAQs on GSTR-2B and GSTR-3B Interaction
Can GSTR-2B be regenerated multiple times?
Yes, until GSTR-3B is filed. There is no limit on regeneration.
What happens if GSTR-3B is filed prematurely?
IMS actions are locked. Errors must be corrected through reversals or amendments in later periods.
Does IMS replace GSTR-2A?
No. GSTR-2A remains an informational statement. IMS actions do not alter it.
FAQs on ITC Eligibility and Time Limits
Does pending status protect ITC from statutory deadlines?
No. Pending status does not extend statutory timelines.
What happens if ITC lapses due to delay?
The credit is permanently lost. IMS provides no relief for missed deadlines.
Are blocked credits filtered automatically by IMS?
No. IMS does not apply statutory eligibility filters. Responsibility rests entirely with the taxpayer.
FAQs on Audits and Notices
Can officers rely on IMS logs during audits?
Yes. IMS logs are system-generated evidence and carry significant evidentiary weight.
Is lack of SOPs a valid ground for adverse inference?
Increasingly, yes. Absence of documented processes is often treated as absence of governance.
Can consistent errors be penalised even if tax impact is low?
Yes. Pattern-based non-compliance is viewed more seriously than isolated mistakes.
FAQs on ERP and System Controls
Is ERP–IMS integration mandatory?
Not legally, but practically essential for medium and large taxpayers.
Are screenshots acceptable evidence?
Screenshots help, but system logs and frozen data extracts carry higher evidentiary value.
Who should have IMS access?
Only trained personnel with clearly defined roles. Broad access increases risk.
FAQs on Credit Notes and Adjustments
Should all credit notes be accepted automatically?
No. Credit notes require the same validation as invoices, including correctness and linkage.
What if a supplier refuses to correct an error?
Commercial escalation becomes necessary. IMS cannot override supplier behaviour.
FAQs on Special Situations
How are inter-company invoices treated?
Exactly like third-party invoices. No relaxed standards apply.
Are zero-value or NIL-tax invoices relevant in IMS?
Yes, if they affect credit linkage or reversals.
Common IMS Myths Clarified
- Myth: IMS is just an advanced reconciliation tool
Reality: IMS is a decision-recording system - Myth: Pending invoices are harmless
Reality: Pending invoices carry deadline risk - Myth: Supplier fault absolves the recipient
Reality: Recipient diligence is independently tested
Key Practitioner Takeaways
- IMS FAQs are process-driven, not legalistic
- Silence or delay is treated as a decision
- Documentation answers most IMS questions
- Consistency matters more than intent
Final Takeaway
IMS has raised practical questions that cannot be answered by statute alone. Sustainable compliance under IMS depends on clarity of process, disciplined behaviour, and consistent execution. Organisations that understand how the system behaves, and respond accordingly, will face fewer disputes, stronger audits, and more predictable outcomes.
Source: ICMAI Handbook on Invoice Management System under GST (January 2026)