Negative Impact of the GST Portal's New Invoice Management System on Quarterly Return Filers

The Goods and Services Tax (GST) portal has recently introduced a significant update in the form of an Invoice Management System (IMS). While this is a step towards improving compliance and reducing errors, it has brought new challenges for taxpayers, especially those filing quarterly GST returns. The non-generation of GSTR-2B for the first two months of a quarter has created hurdles for taxpayers, particularly in discharging their GST liabilities. Let's dive deeper into the implications of this change and explore practical solutions to address these challenges.

What is the Invoice Management System (IMS)?

The Invoice Management System (IMS) is a new functionality rolled out by the GST portal to streamline invoice-related processes. The IMS aims to enhance transparency, improve accuracy, and reduce mismatches in Input Tax Credit (ITC) claims.

Objectives of IMS

• Ensure real-time reporting of invoices.
• Minimize reconciliation errors.
• Facilitate smooth tax compliance for businesses.

Features and Benefits

• Real-time access to invoice-level data.
• Better tracking of transactions between suppliers and buyers.
• Reduced errors in ITC claims.

GSTR-2B: Its Role and Significance

GSTR-2B is a static statement that provides details of ITC available for a taxpayer based on the invoices uploaded by their suppliers. It plays a crucial role in ensuring accurate GST payments and minimizing compliance issues.

Why GSTR-2B is Important

• It helps taxpayers track eligible ITC.
• Ensures accuracy in monthly and quarterly returns.
• Acts as a reference point for reconciling supplier data.

The New Changes to GSTR-2B Generation

Under the new invoice management system, GSTR-2B will now be generated quarterly instead of monthly for taxpayers who file returns on a quarterly basis. However, for the first two months of the quarter, no GSTR-2B will be generated, leaving taxpayers without a clear picture of their ITC during this period.

GST Payment Due Dates for Quarterly Filers

Quarterly filers under the QRMP scheme are required to pay their GST liabilities on a monthly basis, even though they file returns quarterly.

Due Date for Payment of GST

• First Two Months: Payment by the 25th of the following month.
• Quarter-End Month: Due date of Filing of GSTR-3B for the entire quarter.

Methods of GST Payment for Quarterly Filers

The QRMP scheme offers two methods for GST payment:

• Fixed-Sum Method: A pre-determined amount based on previous tax liability.
• Self-Assessment Method: Calculation based on actual sales and purchases during the month.

1. Fixed-Sum Method: Simplified Explanation with Example

The Fixed-Sum Method is an easy way for quarterly GST return filers to pay their tax. Instead of calculating the exact tax every month, they can pay a pre-determined amount based on their past tax liability.

How It Works

• If you filed your GST return last quarter, the system calculates 35% of the tax you paid in cash for that quarter.
• This amount is suggested as your monthly tax for the first two months of the current quarter.

Example:

Let's say in the previous quarter, you paid ₹20,000 as tax using cash.

• Under the Fixed-Sum Method, you'll pay 35% of ₹20,000, which is ₹7,000, as your tax for each of the first two months of the current quarter.

In the third month, you'll file your quarterly GSTR-3B, reconcile your tax liability, and pay any balance amount, if required.

This method is simple and reduces the hassle of monthly calculations. However, it's essential to ensure your final payment at the end of the quarter matches your actual liability.

2. Self-Assessment Method: Simplified Explanation with Example

The Self-Assessment Method allows quarterly GST filers to calculate and pay their tax based on the actual sales and purchases made during each month. Instead of relying on a fixed amount, taxpayers determine their exact GST liability for the month.

How It Works

• Calculate the GST collected on your sales (output tax).
• Subtract the GST paid on your purchases (input tax based on GSTR 2B).
• The remaining amount is your GST liability for that month.

Example:

Imagine you made sales worth ₹1,00,000 in a month, and the GST on these sales is ₹18,000 (output tax). During the same month, you purchased goods worth ₹80,000, and the GST on these purchases is ₹14,400 (input tax).

Now, calculate your monthly GST liability: ₹18,000 (output tax) - ₹14,400 (input tax) = ₹3,600

You'll need to pay ₹3,600 as GST for that month.

This method ensures you pay the exact amount of tax based on your transactions, making it accurate but requiring proper record-keeping and calculations.

Problem after implementation of New Invoice Management System

With the introduction of the Invoice Management System (IMS), the GST portal now generates GSTR-2B quarterly for taxpayers filing quarterly GST returns. However, for the first two months of the quarter, GSTR-2B is not generated.

This creates a significant challenge for taxpayers:

1. Uncertainty in Input Tax Credit (ITC): Without GSTR-2B, taxpayers struggle to accurately calculate the ITC they can claim for the first two months.
2. Difficulty in Discharging GST Liability: Taxpayers must rely on manual reconciliation or estimates, increasing the risk of errors.
3. Increased Compliance Burden: Businesses face additional efforts to track invoices and reconcile data manually.

This issue is especially challenging for small businesses that lack advanced tools or resources for efficient reconciliation.

Impact on Small and Medium Enterprises (SMEs)

SMEs, with limited resources, are likely to face additional compliance costs. The absence of automated tools makes manual reconciliation time-consuming and error-prone.

Steps Quarterly Filers Should Take

1. Maintain an updated record of all transactions.
2. Reconcile ITC manually in the absence of GSTR-2B.
3. Communicate with vendors to ensure timely reporting of invoices.

Possible Solutions to the GSTR-2B Issue

1. Utilize IMS Effectively: Use the IMS to maintain accurate, real-time data of invoices.
2. Manual Reconciliation: Regularly reconcile invoices with suppliers to avoid mismatches.
3. Policy Recommendations: Request authorities to provide provisional GSTR-2B for the first two months.
4. Invest in Technology: Use GST software to automate reconciliation.
5. Hire Experts: Seek help from GST consultants to reduce errors.
6. Vendor Communication: Ensure suppliers upload invoices promptly.

Feedback and Suggestions from the Taxpayer Community

Taxpayers have expressed concerns about the non-generation of GSTR-2B for the first two months. Suggestions include providing a provisional GSTR-2B or enhancing the IMS to generate monthly data for quarterly filers.

Conclusion

The introduction of the Invoice Management System and changes to GSTR-2B generation have undoubtedly created challenges for quarterly filers. However, by leveraging technology, maintaining accurate records, and advocating for policy improvements, taxpayers can navigate these hurdles effectively. The GST portal must also consider providing better support to ensure a smooth transition for all stakeholders.

The author is a qualified Chartered Accountant having more than 12 years of experience in Direct & Indirect Taxation. Currently, he is a working partner of KGMA & ASSOCIATES. He also runs a YouTube channel "ALL ABOUT TAXES" for the latest tax updates. He is also socially active on other social media platforms. His core competency and area of expertise are Income Tax, TDS and also associated with compliance work under Goods and Services Tax, and carries a blend of industrial and professional experience.

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