Updated 11 November 2026. This is a summary of a draft proposal open for public comments, not final law. Read the consultation note on MyGov and check with your CA before changing processes.
Short answer: the CBIC has proposed an "alternate mechanism" for correcting tax liability and input tax credit (ITC) in GST returns, recommended by the GST Council at its 57th meeting. The idea is simple: stop editing numbers in GSTR-3B. Output tax corrections would be made in GSTR-1, GSTR-1A or IFF, and ITC would be managed through the Invoice Management System (IMS) and statutory ledgers (PMT-02A, PMT-02B and a new PMT-10). The changes are proposed from the April 2027 return period, and comments are open on MyGov from 1 to 30 November 2026.
Why the change is being proposed
Today GSTR-3B is auto-filled from GSTR-1 (liability) and GSTR-2B (ITC), but taxpayers can edit both before filing. As A2Z Taxcorp's summary explains, those edits create mismatches that lead to notices. Several portal tools that already exist (IMS, the credit reversal and reclaim statement, the RCM statement) are not formally part of the CGST Rules. The proposal brings them into the rules and moves corrections back to the source.
The main proposals at a glance
| Area | What is proposed |
|---|---|
| Output tax liability | GSTR-3B liability must match GSTR-1 as amended through GSTR-1A or IFF. Earlier-period errors are fixed in the period they are noticed. |
| GSTR-1A | Can amend current or earlier periods (within the section 37(3) time limit) and, for the first time, correct the recipient's GSTIN. Stays optional with no late fee. |
| GSTR-1 tables | Several tables split further, for example B2B into regular, reverse charge, ISD, e-commerce TCS supplies and SEZ; credit/debit notes get a column showing the original supply type. |
| IMS | Formally notified in the rules. Accept, reject or keep pending. No action by GSTR-3B filing means deemed accepted. Bills of entry cannot be rejected. |
| Credit notes | Can stay pending only for a limited period. If the recipient rejects a credit note, the supplier pays that tax back with interest in the next return (new Rule 67B). |
| Non-RCM ITC | Must match GSTR-2B and can be claimed only once GSTR-2B for that period is available. |
| PMT-02A | Credit reversal and reclaim statement becomes statutory. Reclaims cannot exceed the balance. |
| PMT-02B | RCM liability and ITC statement becomes mandatory for reverse-charge payers. RCM ITC cannot exceed RCM tax paid plus the balance. |
| PMT-10 (new) | Application to correct an excess ITC reversal made in an earlier GSTR-3B. |
| DRC-03 Part B (new) | When tax is paid after audit or a notice, Part B lets you report the invoice/debit note so the buyer can claim ITC via GSTR-2B. |
The full proposal also amends GSTR-2B and GSTR-3B tables, PMT-04 and the CGST Rules, and includes a draft circular. TaxGuru and SAG Infotech carry further summaries.
What it means for a typical business
Sellers (suppliers)
- Your GSTR-1 must be right the first time, or fixed through GSTR-1A before GSTR-3B. Correcting the number in GSTR-3B would no longer be the route.
- Credit notes need agreement. If a buyer rejects your credit note in IMS, your liability goes back up, with interest.
- Your invoicing software will need the new GSTR-1 table structure, including e-commerce and SEZ splits.
Buyers (recipients)
- IMS becomes a monthly habit with legal weight. Keep documents pending, rather than accept-and-reverse, when you do not yet meet ITC conditions.
- Reject with care: a wrong rejection affects your supplier and, in turn, your relationship.
- Track reversals and reclaims in PMT-02A, and RCM in PMT-02B, so the portal balances match your books.
Accounts teams and CAs
- Monthly close must follow an order: GSTR-1/IFF, then IMS actions, then GSTR-2B, then GSTR-3B.
- Reconciliations become simpler in theory, because the return should match the source data, but there is less room to adjust at the last minute.
What your billing or ERP software should prepare for
- New GSTR-1 mapping: invoice types tagged for the new sub-tables (reverse charge, ECO-TCS, SEZ, B2C split by e-commerce involvement).
- Credit/debit note linking: store the original invoice and the original supply type for every note.
- Amendment workflow: track what was reported in GSTR-1 and what needs a GSTR-1A, including a corrected recipient GSTIN.
- IMS sync: pull IMS data, record accept/reject/pending decisions with reasons and dates, and alert before GSTR-3B.
- Ledgers: maintain reversal/reclaim and RCM balances that you can match against PMT-02A and PMT-02B.
- Close checklist: block GSTR-3B preparation until GSTR-2B is available and IMS actions are complete.
Our guide to the GST Invoice Management System (IMS) covers the current accept/reject/pending workflow, and our post on GSTR-3B interest under Rule 88B explains how interest is worked out today.
How to give your comments
The consultation runs from 1 to 30 November 2026 on MyGov. Reports note that once you submit comments for an area you cannot edit them, so prepare them first. Industry bodies and CA associations usually submit joint comments too, so small businesses can also raise points through them.
What to do now
- Nothing changes in your returns yet. Keep filing as you do today.
- Start cleaning up habits that the proposal would end, such as editing GSTR-3B figures away from GSTR-1 and 2B.
- Ask your software vendor about their plan for the April 2027 change.
- Watch for the final notification after the consultation. We will update this post.
Need GST-ready software?
Nextinera builds ERP and billing systems with GST return preparation, IMS reconciliation and audit trails. See our GST billing software checklist or book a free call.