On 8 October 2025, the Goods and Services Tax (GST) Network, under the aegis of the Ministry of Finance, Government of India, issued an important advisory titled “Advisory on GST Return and Invoice Management System (IMS)”. The advisory reaffirms the procedural framework for Input Tax Credit (ITC) auto-population, GSTR-2B generation, and credit note handling, following the implementation of IMS.
This clarification is crucial for taxpayers and professionals managing high transaction volumes, as it ensures continuity in ITC reporting while introducing procedural flexibility for real-time invoice management.
No Change in ITC Auto-Population Mechanism
The advisory categorically confirms that the auto-population of ITC from GSTR-2B to GSTR-3B remains unchanged. The transition to IMS does not alter the existing mechanism or data flow process.
Key points:
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ITC will continue to auto-populate from Form GSTR-2B to Form GSTR-3B.
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The process is fully system-driven, eliminating any requirement for manual data entry or validation at this stage.
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All existing provisions under Section 16 and Section 17 of the CGST Act, 2017, and Rules 42 and 43 of the CGST Rules, remain fully applicable for determining eligibility, reversals, and apportionment of ITC.
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The IMS merely acts as an interface for viewing, reconciling, and tracking supplier invoices, and does not interfere with the credit flow between 2B and 3B.
This ensures data integrity, compliance uniformity, and consistency in monthly ITC computation.
GSTR-2B Generation and Flexibility in Regeneration
The advisory reiterates that GSTR-2B will continue to be generated automatically on the 14th day of each month, based on suppliers’ GSTR-1 and IFF filings. However, under the IMS framework, taxpayers now gain procedural flexibility:
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Automatic generation: GSTR-2B will be system-generated every month on the 14th, without any manual intervention.
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Post-generation actions: Taxpayers may perform reconciliation activities in IMS even after the 2B is generated—such as marking invoice mismatches, tagging disputed invoices, or tracking delayed filings.
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Regeneration window: Based on the updates made in IMS after the initial 2B generation, taxpayers can regenerate GSTR-2B any time before filing GSTR-3B.
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The regenerated GSTR-2B will reflect the latest invoice data, ensuring precision in ITC reporting and reconciliation.
This controlled flexibility promotes data transparency and allows taxpayers to align GSTR-3B with the most accurate, supplier-validated data available.
Credit Note Handling – Effective from October 2025 Tax Period
The advisory introduces procedural clarity for credit note reflection and reconciliation from the October 2025 return period onward.
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Credit note data filed by suppliers will continue to be captured automatically in GSTR-2B generated on the 14th of the subsequent month.
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Taxpayers can perform credit note-related actions in IMS—such as acceptance, reconciliation, or dispute marking—until the date of GSTR-3B filing.
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Upon any such post-generation actions, GSTR-2B can be regenerated to include updated credit note data prior to 3B submission.
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This ensures that both the ITC ledger and liability adjustments are synchronized with the most current data set.
For professionals, this update reinforces that timely supplier coordination remains critical to ensure accurate reflection of credit notes and prevent mismatched credit reversals under Rule 37A.
Compliance and Systemic Implications for Taxpayers
This advisory is not a procedural overhaul but a digital synchronization enhancement. The IMS serves as a facilitative tool for real-time invoice and credit management. The following implications merit professional attention:
a. Automation Continuity:
Auto-population remains system-driven, safeguarding uniformity across returns and reducing manual discrepancies.
b. Enhanced Reconciliation Discipline:
IMS allows continuous reconciliation between supplier-uploaded invoices and recipient records, enabling proactive dispute management before filing GSTR-3B.
c. Regeneration Flexibility as a Safeguard:
The regeneration feature ensures last-mile correction of data, thereby reducing audit risks and potential mismatches during departmental verification.
d. Record-Keeping and Audit Trail:
Taxpayers should maintain detailed logs of IMS actions, regenerated GSTR-2B files, and correspondence with suppliers, as these will serve as key evidence in GST audits or adjudication.
e. Governance Alignment:
Enterprises should update their internal GST SOPs to include IMS-based reconciliation workflows, ensuring alignment between accounting systems (ERP) and the GST portal data.
Conclusion
The GST Advisory dated 8 October 2025 underscores that the Invoice Management System (IMS) is a functional enhancement designed to strengthen transparency, control, and synchronization across GST returns. It introduces greater operational flexibility without altering the core statutory process of ITC auto-population from GSTR-2B to GSTR-3B.
