Before October 2024, ITC was largely passive. Invoices from suppliers auto-populated in GSTR-2B and recipients had limited control over what entered their credit ledger. If a supplier filed a wrong invoice, the recipient’s ITC was affected – and resolving it required back-and-forth outside the GST portal.
The Invoice Management System (IMS), launched on the GST portal on October 14, 2024, changes that. For the first time, recipients have a structured, portal-level workflow to review every inward invoice and take a deliberate action: accept it, reject it, or hold it as pending.
For CAs and finance teams managing large supplier bases, IMS is not optional reading. From January 2026, stricter ITC validations make IMS the primary mechanism for ITC claim control. Miss an action or process bulk invoices incorrectly, and the consequences flow directly into GSTR-2B and downstream into GSTR-3B.
This blog covers the complete recipient IMS flow – what each action means, how bulk invoice actions work, how rejection reasons can be customized and communicated back to suppliers, and how Cygnet’s platform automates the entire workflow.
What Is the Invoice Management System (IMS)?
IMS is a real-time dashboard on the GST portal that shows recipients every invoice filed by their suppliers in GSTR-1, IFF, or GSTR-1A. The recipient reviews each invoice and takes one of four actions before filing their GSTR-3B.
Before IMS, the GSTR-2B was generated automatically based on supplier filings. The recipient had no say. IMS flips this – now the recipient’s explicit action (or deliberate inaction) determines what enters GSTR-2B as eligible ITC.
IMS is a facilitation tool, not an additional compliance burden. If a recipient takes no action on an invoice, it is treated as Deemed Accepted and flows into GSTR-2B as eligible ITC. Intervention is only needed when a recipient wants to Reject or Pend an invoice.
When Did IMS Go Live?
IMS was made available on the GST portal from October 1, 2024. The Supplier View – which lets suppliers see what action a recipient has taken on each of their invoices – was introduced on October 14, 2024. From the October 2024 tax period onwards, recipient actions in IMS directly determine what appears in GSTR-2B.
Who Does IMS Apply To?
- All regular GST taxpayers who file GSTR-3B.
- QRMP taxpayers – though their GSTR-2B is generated quarterly, not monthly.
- Recipients of invoices filed in GSTR-1, IFF (Invoice Furnishing Facility), and GSTR-1A.
RCM (Reverse Charge Mechanism) supplies and invoices ineligible under Section 16(4) or POS rules do not appear in the IMS dashboard. They flow directly into GSTR-3B without any IMS action.
The Four IMS Actions – What Each One Means
Every invoice in the IMS dashboard can be actioned in one of four ways. Each has a specific impact on GSTR-2B and the recipient’s ITC position.
| Action | What It Means | Impact on GSTR-2B | ITC Impact |
| Accept | Recipient confirms the invoice is correct and eligible for ITC | Moves to ITC Available section of GSTR-2B | Auto-populates as eligible ITC in GSTR-3B Table 4(A) |
| Reject | Recipient disputes the invoice – wrong details, duplicate, or not received | Moves to ITC Rejected section of GSTR-2B | Does not auto-populate in GSTR-3B; ITC not claimed |
| Pending | Recipient is not ready to decide – needs more time or information | Not included in GSTR-2B for the current month | Carried forward in IMS for action in subsequent months |
| Deemed Accepted | No action taken before GSTR-2B generation cutoff | Treated as Accepted; flows into ITC Available | Auto-populates as eligible ITC in GSTR-3B |
Deemed Acceptance is the most critical risk for high-volume taxpayers. If a recipient does not action an invoice before GSTR-2B is generated on the 14th of the following month, it is automatically accepted. For businesses receiving thousands of invoices, this means wrong or ineligible invoices can enter GSTR-2B without review.
Accept – When to Use It
Accept an invoice when:
- The invoice matches your purchase order, GRN (Goods Receipt Note), and internal records.
- The GSTIN, invoice number, date, taxable value, HSN/SAC code, and tax amounts are correct.
- The ITC is eligible – the goods or services are used for business purposes, are not blocked under Section 17(5), and the invoice belongs to the recipient.
- The supplier has filed their GSTR-1 or GSTR-1A and the invoice is within the ITC claim window under Section 16(4).
Reject – When to Use It
Reject an invoice when:
- The invoice was never received – it is filed by the supplier but does not correspond to any actual supply.
- The invoice contains errors – wrong GSTIN, wrong taxable value, wrong tax rate, or wrong supply type.
- It is a duplicate – the same invoice has already been accepted and processed.
- The goods were returned or the service was not rendered.
- The ITC is blocked under Section 17(5) – for example, motor vehicle purchase, personal use, or food and beverages.
Rejection has consequences beyond just excluding the ITC. For certain document types, a rejection by the recipient triggers a liability increase for the supplier in the following period. The specific cases are:
- Original credit note rejected by the recipient.
- Upward amendment of a credit note rejected by the recipient.
- Downward amendment of a credit note rejected by the recipient – where the original credit note was also rejected.
- Downward amendment of an invoice or debit note rejected – where the original was accepted and GSTR-3B was filed.
This supplier liability mechanism is intentional. It creates accountability for suppliers who issue incorrect credit notes or make downward amendments after the recipient has already filed returns based on the original document.
Pending – When to Use It
Pending is the right action when:
- A three-way match (PO, GRN, invoice) is not yet complete.
- The invoice is under dispute with the supplier and resolution is expected next month.
- The recipient is waiting for credit notes or debit notes to be filed before acting on the invoice.
- There is internal approval delay – the invoice is genuine but the approver has not cleared it yet.
Pending records stay on the IMS Dashboard indefinitely until the recipient takes a final action. They can be accepted or rejected in any future month, as long as the ITC claim stays within the Section 16(4) window.
Pending is NOT allowed in the following scenarios: (1) Upward amendment of a credit note regardless of earlier action, (2) Downward amendment of a credit note where the original was rejected, (3) Downward amendment of an invoice or debit note where the original was accepted and GSTR-3B has been filed. For these, the recipient must Accept or Reject – Pending is locked out.
The Complete Recipient IMS Flow
Here is the end-to-end flow from a supplier filing an invoice to the recipient’s ITC being finalized in GSTR-3B.
Step-by-Step Recipient Flow
- Supplier saves or files invoice in GSTR-1/IFF/GSTR-1A. The invoice immediately appears in the recipient’s IMS dashboard – even before the supplier files the return. Saved records are visible but they only flow into GSTR-2B after the supplier files.
- Recipient sees the invoice on the IMS dashboard. The dashboard shows all inward invoices for the period, grouped by supplier, along with their current action status: No Action, Accepted, Rejected, or Pending.
- Recipient reviews the invoice. This is where the reconciliation step happens – matching the IMS invoice against internal purchase records, GRN data, and PO details.
- Recipient takes action: Accept, Reject, or Pending. This can be done at any time between the supplier saving the record and the recipient filing their GSTR-3B.
- Draft GSTR-2B is generated on the 14th of the following month. Only filed supplier invoices are included. Accepted and Deemed Accepted invoices go into ITC Available. Rejected invoices go into ITC Rejected. Pending invoices are excluded from GSTR-2B entirely.
- Recipient can still take actions after the 14th until GSTR-3B is filed. However, any change in action after the 14th requires the recipient to recompute GSTR-2B manually from the IMS dashboard before filing GSTR-3B.
- Recipient files GSTR-3B. All accepted and deemed accepted invoices are reflected as eligible ITC in Table 4(A). After GSTR-3B is filed, no further IMS actions are possible for that period. Accepted, Deemed Accepted, and Rejected records move out of the IMS dashboard. Pending records remain for future action.
The GSTR-2B Sequencing Rule
From IMS onwards, GSTR-2B generation is sequential. The system generates GSTR-2B for a return period only if GSTR-3B for the previous period has been filed. This means:
- If a recipient has not filed September GSTR-3B, October GSTR-2B will not be generated.
- This creates a cascading compliance obligation – filing arrears immediately block the current period’s ITC computation.
For CAs managing multiple clients, this sequencing rule makes GSTR-3B filing arrears much more consequential than before. One missed month blocks the next month’s GSTR-2B entirely.
What Happens When a Supplier Amends an Invoice
Amendments create specific rules in IMS that CAs need to be aware of:
| Scenario | IMS Behaviour |
| Supplier amends a saved (unfiled) invoice in GSTR-1 | Amended invoice replaces the original in IMS; earlier recipient action is reset |
| Supplier amends a filed invoice via GSTR-1A | Amendment flows into IMS; ITC flows into GSTR-2B of the subsequent month only |
| Original and amended record fall in the same GSTR-2B period | Only the amended record is considered for ITC calculation |
| Original and amended record fall in different GSTR-2B periods | Recipient must action the original record and file GSTR-3B before actioning the amended record |
Rejection Reasons – Customization and Supplier Communication
One of the most operationally important questions around IMS is whether rejection reasons can be customized and whether they are automatically communicated back to suppliers. Here is the complete picture.
What the GST Portal Provides
When rejecting an invoice on the GST portal, the recipient can add a rejection remark. The portal provides a free-text field for this purpose. The remark is visible to the supplier in their Supplier View on the IMS dashboard.
Can Rejection Reasons Be Customized?
On the GST portal itself, rejection remarks are free-text – there is no drop-down or pre-set category list. The portal does not enforce a standardized reason code. This means:
- Recipients can write any remark they choose.
- There is no structured reason code that maps to a specific supplier corrective action.
- The remark is visible in the Supplier View but not pushed as a notification to the supplier.
For enterprises managing thousands of rejections across a large supplier base, this free-text approach creates inconsistency. The same underlying error – wrong GSTIN – may be described differently by different team members, making reporting and supplier communication tracking unreliable.
Automatic Supplier Communication on Rejection
The GST portal does not automatically send a notification or email to the supplier when an invoice is rejected. The supplier sees the rejection status only when they log into their IMS Supplier View.
This passive visibility is a practical problem. Suppliers with large volumes of outward invoices may not check their Supplier View daily. By the time they see the rejection, the window to amend via GSTR-1A and have the correction reflect in the same month’s GSTR-2B may have closed.
Compliance platforms solve this by:
- Automated rejection alerts: An email is sent to the supplier’s registered contact as soon as the recipient marks an invoice as Rejected. The message includes the invoice number, rejection reason, and the corrective action expected.
- Correction tracking: Once the supplier files a GSTR-1A amendment, the compliance platform detects the correction in the next IMS refresh and updates the rejection status automatically.
- Supplier rejection dashboard: Both the recipient’s team and the supplier can see a consolidated view of all pending rejections, corrective actions taken, and timelines – avoiding the back-and-forth of email chains.
Bulk Invoice Actions in IMS
For businesses receiving hundreds or thousands of invoices every month, processing each one individually on the GST portal is not feasible. IMS provides bulk action functionality – but it has specific limits and operating constraints that every CA needs to know.
The 500-Invoice Batch Limit
The GST portal supports bulk actions for up to 500 invoices per batch. This is a hard portal limit. A recipient with 5,000 invoices in a period needs to execute at least 10 separate batch operations to process all of them.
| Invoice Volume | Batches Required | Portal Actions Needed | Typical Manual Processing Time |
| Up to 500 | 1 batch | 1 upload and action | 1 to 2 hours |
| 500 to 2,500 | 2 to 5 batches | 5 to 10 upload and action cycles | 4 to 8 hours |
| 2,500 to 5,000 | 5 to 10 batches | 10 to 20 upload and action cycles | 1 to 2 days |
| 5,000 and above | 10+ batches | 20+ upload and action cycles | 2 to 5 days without automation |
The Bulk Action Workflow on the GST Portal
Here is the step-by-step process for executing bulk IMS actions on the portal:
- Start the review cycle on the 1st of the month. Do not wait for the 14th GSTR-2B generation date. Starting early gives the team time to resolve exceptions and communicate with suppliers before the cutoff.
- Download the IMS dashboard data. Export the full invoice list for the period in Excel format from the IMS dashboard. This file becomes the working document for bulk review.
- Segment invoices by category. In the exported file, classify invoices into: auto-accept (matches PO/GRN and internal records), needs review, reject, and pending. This segmentation drives the bulk action decisions.
- Apply decisions using compliance software. Use a GST compliance platform to auto-apply Accept/Reject/Pending decisions based on reconciliation rules. The platform generates a batch-ready action file.
- Execute bulk portal actions in batches of up to 500. Upload the action file to the GST portal’s IMS bulk action interface. Each batch must be completed before the next is started. Track the portal confirmation for each batch.
- Add rejection remarks for all rejected invoices. Every rejected invoice should have a remark. This is mandatory for supplier communication and internal audit trail purposes.
- Recompute GSTR-2B after all actions are complete. If any action was taken after the 14th, or if actions were changed after the initial GSTR-2B draft was generated, the recipient must manually trigger a GSTR-2B recompute from the IMS dashboard before filing GSTR-3B.
- Reconcile GSTR-2B with GSTR-3B. Verify that the ITC available in the recomputed GSTR-2B matches what the recipient intends to claim in GSTR-3B Table 4(A). Then file GSTR-3B.
Bulk Action Decision Rules – What to Auto-Accept and What to Route for Review
Not every exception requires manual intervention. A well-configured ISD reconciliation platform allows teams to define bulk action rules at the document type level across all exception buckets, ensuring high-volume routine cases are resolved automatically while genuine discrepancies are escalated for review.
Across all buckets – Matched, Matched by Tolerance, GSTR-6A Only, Mismatched, and Near Matched – actions can be configured based on document type, such as invoices, debit notes, or credit notes, allowing different rules to apply depending on the nature of the document.
For the Mismatched and Near Matched buckets, an additional and critical layer of control is available through the Reasons field. Since not all mismatches carry the same weight, the reason behind the discrepancy drives the action:
- Where the reason points to a significant or unresolvable discrepancy – such as a supplier GSTIN mismatch, tax rate difference, or a document that cannot be mapped – the record is flagged for rejection and routed for manual review.
- Where the reason indicates a minor or explainable variance – such as a rounding difference, a known amendment in transit, or a field-level mismatch within acceptable bounds – the system can be configured to auto-accept the record without manual intervention.
This reason-driven logic within the Mismatched and Near Matched buckets ensures that bulk actions remain precise – high-confidence cases move through automatically, while ambiguous or high-risk exceptions always land with the right person for a decision.
Compliance Guardrails for Mass Accept and Reject
Bulk actions carry compliance risk if applied incorrectly. These guardrails prevent errors:
- Never auto-accept without a three-way match: Accepting invoices that have not been matched against PO and GRN means claiming ITC without verifying the underlying supply. This is an ITC accuracy risk.
- Do not batch-reject without a valid reason: Rather than batch-rejecting records, keep them pending for review. Cygnet’s portal offers strong filtering capabilities through the Actions filter, allowing teams to quickly surface all pending records and take informed, record-level decisions – ensuring no legitimate ITC claim is lost to a hasty rejection.
- Recompute GSTR-2B after every batch: If bulk actions are executed after the 14th, the GSTR-2B must be recomputed before filing GSTR-3B. Skipping this step means the GSTR-3B ITC figure is based on outdated GSTR-2B data.
Supplier View in IMS – What Suppliers See
The Supplier View, introduced on October 14, 2024, gives suppliers visibility into the action status of every invoice they have filed. This is the mechanism through which rejection reasons reach the supplier side.
What Is Visible in the Supplier View
| Information | Details |
| Invoice action status | Accept, Reject, Pending, or No Action Taken for each filed invoice |
| Rejection remark | Free-text remark entered by the recipient at the time of rejection |
| Invoice details | Invoice number, date, GSTIN, and tax amounts as filed |
How Suppliers Should Use This Information
- For rejected invoices: Review the rejection reason, identify the error, and either file a GSTR-1A amendment or issue the appropriate credit note or debit note. Corrections must be done before the recipient files their GSTR-3B for the correction to reflect in the same period’s GSTR-2B.
- For pending invoices: Contact the recipient to understand what is holding up the action. Supply the missing document – GRN confirmation, corrected invoice, or credit note – to enable the recipient to accept.
- For no-action invoices: These will be deemed accepted at GSTR-2B generation. No supplier action needed unless the recipient later contacts to dispute.
A supplier whose invoice is rejected in IMS needs to act quickly. The window to file a GSTR-1A amendment and have the correction appear in the same period’s GSTR-2B is narrow. After the recipient files GSTR-3B, the rejection is locked for that period.
IMS Accept/Reject Workflows on Cygnet’s Platform
Cygnet’s platform builds the IMS workflow into the same environment as GSTR-2B reconciliation, GSTR-3B filing, and supplier management. The entire accept/reject cycle – from invoice review to bulk action to supplier communication to GSTR-2B recompute – runs in one place.
Platform Capabilities for IMS
| IMS Workflow Need | How Cygnet Handles It |
| Live IMS dashboard sync | Portal IMS data synced automatically; no manual export required |
| Automated decision rules | Pre-configured rules auto-accept, auto-reject, or auto-pend based on match outcome and supplier category |
| Automated supplier rejection alerts | Email/portal notification sent to supplier immediately on rejection with reason and corrective action guidance |
| Bulk action generation | Batch files generated in portal-compatible format for up to 500 invoices per batch |
| Batch execution tracking | Each batch tracked for portal submission and confirmation status |
| GSTR-2B recompute trigger | Platform flags when recompute is needed and enables one-click trigger |
| GSTR-2B to GSTR-3B reconciliation | ITC from recomputed GSTR-2B cross-checked against GSTR-3B before filing |
| Pending invoice ageing tracker | Tracks invoices approaching the Section 16(4) ITC claim deadline – teams can apply the pending filter to identify and act on time-sensitive records before the deadline lapses. |
| Supplier View integration | Supplier can see their rejection status and reasons directly via the Cygnet vendor portal |
What This Means for CAs Managing Large Portfolios
- No manual batch counting: The platform automatically processes and uploads the entire action file in one go, managing the complete upload sequence without any manual intervention.
- No missed recomputes: Every post-14th action triggers an automatic recompute reminder.
- No supplier chasing: Rejection alerts go out automatically. The CA’s team sees the supplier’s response timeline in the rejection tracker, not in a cluttered email chain.
- Clean audit trail: Every action – accept, reject, pending – is timestamped and logged with the reason code and the team member who took the action.
Common IMS Mistakes and How to Avoid Them
Relying on Deemed Acceptance
Not reviewing invoices and letting them default to Deemed Accepted is the most common mistake. A large, wrongly filed invoice becomes an accepted ITC claim without verification. The recipient may later face a demand notice for wrongly claimed ITC.
Rejecting Without Adding a Reason
Rejecting invoices without a remark means the supplier does not know what to fix. They may refile the same incorrect invoice the next month.
Fix: Make rejection reasons mandatory in your team’s workflow.
Forgetting to Recompute GSTR-2B After Post-14th Actions
Taking an IMS action after the 14th and then filing GSTR-3B without recomputing GSTR-2B means GSTR-3B ITC data is based on the stale draft GSTR-2B from the 14th.
Fix: Always recompute GSTR-2B after any post-14th IMS action. File GSTR-3B only from the recomputed GSTR-2B.
Keeping Invoices Pending Beyond the Section 16(4) Window
Pending invoices that age beyond the ITC claim deadline under Section 16(4) cannot be accepted after that point. The ITC is permanently lost.
Fix: Track all Pending invoices with a deadline date. Review and act on them before the Section 16(4) cutoff.
Not Checking the Sequencing Rule Before Starting
If GSTR-3B for the previous period is not filed, GSTR-2B for the current period will not generate – regardless of IMS actions taken.
Fix: Confirm that the previous period’s GSTR-3B is filed before beginning the current period’s IMS review cycle.
Frequently Asked Questions
Can I change an Accept to Reject after GSTR-2B is generated?
Yes – you can change an action at any time before filing GSTR-3B for that period. However, any change after the 14th (GSTR-2B generation date) requires you to recompute GSTR-2B before filing GSTR-3B. After GSTR-3B is filed, the action is locked.
Does the supplier automatically know when I reject their invoice?
The supplier can see the rejection status in their IMS Supplier View on the GST portal. However, the portal does not send an automatic email or notification. For timely supplier communication, a compliance platform with automated rejection alerts is needed.
What happens to an invoice I mark as Pending from October 2024?
It stays in the IMS dashboard until you take a final action – Accept or Reject. It will not appear in any GSTR-2B until you accept it. However, you must accept it before the Section 16(4) ITC claim deadline, which is the earlier of the date of filing the annual return for the year or November 30 of the following financial year.
If the supplier amends an invoice after I have rejected it, do I need to act again?
Yes. The amended invoice appears in IMS as a new record. Your rejection of the original does not automatically apply to the amendment. You need to review the amended invoice and take a fresh action. If the original and the amendment fall in different GSTR-2B periods, you must have filed GSTR-3B for the original period before acting on the amendment.
Does IMS apply to RCM invoices?
No. Invoices attracting Reverse Charge Mechanism (RCM) do not flow through IMS. They are directly populated in GSTR-3B Table 3.1(d) without any IMS action by the recipient.
What is the maximum batch size for bulk IMS actions on the Government portal?
The GST portal supports a maximum of 500 invoices per bulk action batch. For higher volumes, multiple sequential batches are required.
Can I take IMS actions for a period after the GSTR-3B is filed?
No. Once GSTR-3B for a period is filed, all IMS actions for that period are locked. Accepted, Deemed Accepted, and Rejected records move out of the dashboard. If you need to correct an ITC claim after GSTR-3B is filed, you need to use the amendment or reversal mechanism in a subsequent GSTR-3B.
Conclusion
IMS is the most significant change to ITC management since GST was introduced. For the first time, the recipient controls what enters their GSTR-2B. That control comes with responsibility – the Deemed Acceptance rule means inaction has consequences, and bulk action errors can affect hundreds of invoices in a single incorrect upload.
The accept/reject workflow is straightforward when invoice volumes are small. For mid-size and large businesses, it requires a disciplined process: start early, automate the straightforward decisions, route exceptions to human review, communicate rejections to suppliers immediately, and always recompute GSTR-2B before filing GSTR-3B.
Customised rejection reasons, communicated automatically to suppliers, convert IMS from a passive compliance checkpoint into an active supplier quality management tool. Suppliers who receive clear, structured rejection messages fix errors faster and file correct invoices more consistently – which directly reduces the reconciliation burden on the recipient’s team every month.
Cygnet’s platform brings all of this together – automated decisions, structured rejection communication, batch management, GSTR-2B recompute tracking, and a full audit trail – in one place. The goal is the same as with all GST compliance workflows: the right ITC, in the right period, with the documentation to stand behind every decision.





