GSTN : Into Pending Option for CN & Declaration of Reversal AMT in IMS

GST IMS Introduction of Pending Option for CN & Declaration of Reversal AMT in IMS w.e.f. Oct 2025 : GSTN

Background – Introduction of “Pending” Option

• The GSTN has introduced a new facility in the IMS on the GST portal, allowing taxpayers to mark Credit Notes as “Pending” for one tax period.
• Additionally, the IMS functionality has been enhanced to enable taxpayers to declare the exact Input Tax Credit reversal amount upon acceptance of such Credit Notes.
  This aims to provide greater flexibility in ITC reconciliation & help resolve long-standing business disputes between suppliers and recipients.
• As per the Goods and Services Tax Network advisory dated 17 October 2025, Invoice Management System has been enhanced to allow recipient taxpayers to mark credit notes (and certain amendments) as “Pending” for one tax-period instead of immediately accepting or rejecting them.
• Taxpayers (recipients) can now mark Credit Notes & specific amendment documents as “Pending” for one tax period (month/quarter). This feature allows additional time for reconciliation before accepting or rejecting supplier documents.
• At the time of acceptance of such credit notes/amendments, the taxpayer now has the option to declare the amount of Input Tax Credit to be reversed, i.e., full or partial reversal, rather than automatic full reversal.

Key Features of the New Facility

Which documents this applies in the following – The new “Pending” option is available for the following records:

1. Credit notes or upward amendment of credit notes.
2. Downward amendment of credit note where original credit note was rejected.
3. Downward amendment of invoice/debit note only where original invoice already accepted and GSTR-3B filed.
4. ECO-Document downward amendment only where original accepted & GSTR-3B filed.

Duration for Keeping Records Pending- Key operational details

• For monthly taxpayers (recipients): Monthly filers-One month (until due date of next GSTR-3B). The record may be kept in “Pending” status for one tax period (one month). Illustration : Monthly Filer: GSTR-1 filed on 10 Nov 2025 (for Oct 2025) : Credit Notes can be kept pending up to 20 Dec 2025 (due date for GSTR-3B of Nov 2025).
• For quarterly-filers (recipients): Quarterly filers: One quarter (until due date of next quarter’s GSTR-3B). The period allowed is one tax period (one quarter). Illustration : Quarterly Filer:
  GSTR-1 filed on 10 Jan 2026 (for Oct–Dec 2025) : Credit Notes can be kept pending up to 22 / 24 Apr 2026 (due date for GSTR-3B of Jan–Mar 2026).
• After expiry, “Pending” status auto-disables and unacted records are deemed accepted. In other words; After expiration of the allowed “Pending” period, the system will disable the “Pending” status and if no action is taken, the record will be deemed accepted.

Flexibility in ITC Reversal Declaration

On accepting Credit Notes or amendments, taxpayers now have the option to declare the exact amount of Input Tax Credit (ITC) to be reversed. This helps in cases where ITC was not availed or partially availed, avoiding unnecessary full reversal.. IMS System prompt: “Whether ITC needs to be reduced for the selected record(s)?”

• No : No reversal, as ITC not availed.
• Yes : Option to specify full or partial reversal amount.
• When accepting the record, the system now asks: “Whether Input Tax Credit needs to be reduced for the selected record(s)?”  If No, means no Input Tax Credit was availed and so no reversal; If Yes, then either full reversal or declare amount for partial reversal.
• At the time of taking “Reject” or “Pending” action, taxpayers may (and in certain cases must) give optional/mandatory remarks improving transparency between recipient and supplier.

New Functionalities Introduced- New Option for Remarks

• Taxpayers can now add remarks while marking documents as Reject or Pending. Remarks are mandatory in cases of partial or no reversal, promoting transparency between supplier and recipient.
  • Taxpayers can mark eligible records as “Pending” for one tax period.
  • Option to declare the “Amount of ITC to be reduced” at the time of accepting Credit Notes or amendments.
  • Option to add remarks while marking records as pending or Reject, improving transparency.

Prospective Application

These changes are prospective, i.e., applicable from the October 2025 tax period onwards. The facility does not retrospectively apply to earlier tax periods in the way the change is structured. . Any records reported in GSTR-1 for earlier tax periods will not reflect these new features. Examples:

Credit Notes  Date	Reported In	Filing Date	Availability of New Facility
15 Sep 2025	GSTR-1 of Sep 2025	11 Oct 2025	No Pending Option
15 Oct 2025	GSTR-1 of Oct 2025	11 Nov 2025	Pending Option Available
15 Mar 2025	GSTR-1 of Oct 2025	11 Nov 2025	Pending Option Available (GSTR-2B Period: Oct 2025)
20 Sep 2025	GSTR-1A of Sep 2025	14 Oct 2025	Pending Option Available (GSTR-2B Period: Oct 2025)

Official link: https://www.gst.gov.in/newsandupdates/read/631

Practical Implications GST IMS Introduction of Pending Option for CN & Declaration of Reversal AMT in IMS

• For businesses: Helps manage CN disputes, improves ITC accuracy, and prevents mismatched reversals.
• Records Covered Under “Pending” Option- Available for:
  • Credit Notes and upward amendment of CNs.
  • Downward amendment of CN where original CN was rejected.
  • Downward amendment of Invoice/Debit Note where original invoice already accepted and GSTR-3B filed.
  • ECO-Document downward amendment (for e-commerce operators) where original accepted and GSTR-3B filed.
• For auditors: Introduction of Table 6A1 in GSTR-9 : Table 6A1 introduces better traceability of ITC movement between years. As noted by Bhogavalli Mallikarjuna Gupta (RSM India), a new Table 6A1 has been added to GSTR-9 to improve accuracy of ITC reporting and reconciliation with prior years. This change is aims to facilitate desk reviews and reduce scrutiny and litigation. Moreover that Data consistency expected between Table 12 (ITC reversal), Table 13 (ITC availed), & Table 6A1 (current year).

Impact and Benefits- “Pending” Option Available

• Ease of Reconciliation: Reduces disputes on ITC reversals related to Credit Notes.
• Transparency: Introduces a clear audit trail through remark entries.
• Compliance Efficiency: Enables accurate reflection of ITC adjustments in GSTR-2B and GSTR-3B.
• Dispute Reduction: Supports better supplier-recipient coordination, reducing litigation and mismatch notices.

For GST officers: Simplifies verification and reduces manual intervention.

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