Many businesses park disputed bills or unreceived goods in the IMS pending queue during regular monthly filing. While keeping records pending is normal across financial year 2026-27, prior-year invoices from financial year 2025-26 face the hard statutory cut-off established under GST law.
The Section 16(4) cut-off and IMS pending records
The time limit to avail input tax credit for any invoice or debit note relating to a financial year is governed by Section 16(4) of the CGST Act, which sets the cut-off as 30 November following the end of the financial year, or the date of filing the annual return, whichever is earlier. For supplies pertaining to financial year 2025-26, this statutory deadline falls on 30 November 2026.
According to the official GSTN Advisory on Additional FAQs on IMS, records marked as pending in the IMS dashboard do not form part of GSTR-2B and GSTR-3B for that period and roll over to subsequent periods. If you leave a financial year 2025-26 invoice marked as pending into December 2026, you cannot claim the credit in any subsequent GSTR-3B because the Section 16(4) time window closes.
Fatal mistake: Leaving a financial year 2025-26 inward invoice as pending on IMS past the November 2026 filing cycle excludes it from GSTR-2B. Once 30 November passes, that input tax credit is blocked permanently by law.
Deemed acceptance versus pending action
The GST portal handles inaction and active pending status differently:
- No action taken: As clarified in the Revised Advisory on IMS, where no action is taken by the recipient on an inward supply record filed by the supplier in GSTR-1, GSTR-1A, or IFF, the record is treated as deemed accepted at the time of GSTR-2B generation on the 14th of the month.
- Pending action taken: If you actively marked an invoice as pending, it remains deferred and rolls over to the next tax period without entering GSTR-2B.
- Supplier amendments: Under the GSTN FAQs on IMS, when a supplier files an amendment via Form GSTR-1A or a subsequent Form GSTR-1, the amended record flows into your IMS dashboard as a fresh document, resetting any previous action.
Review your earlier operational workflow in our companion guide on handling IMS pending invoices.
Steps to clear pending invoices in November 2026
- Log in to GST portal: Navigate to Services → Returns → Invoice Management System (IMS) Dashboard.
- Filter by financial year: Select inward supplies and filter document dates between 1 April 2025 and 31 March 2026.
- Review pending list: Identify all entries currently sitting with the status marked as Pending.
- Change status to Accept: For all verified inward supplies where goods or services were received, switch the status to Accept.
- Recompute GSTR-2B: After updating actions on the dashboard, recompute your GSTR-2B so the accepted invoices populate Table 4A of Form GSTR-3B.
Worked calculation: pending ITC risk for FY 2025-26
Consider Shiva Traders, a manufacturing firm holding three vendor invoices from FY 2025-26 on their IMS dashboard in early November 2026. The firm files its October 2026 GSTR-3B on 20 November 2026.
| Invoice | Date | Taxable Value | IGST | Action in IMS | ITC Status on 30 Nov 2026 |
|---|---|---|---|---|---|
| INV-841 | 14 Jan 2026 | ₹2,00,000 | ₹36,000 | Changed to Accept | ₹36,000 Claimed in 2B |
| INV-902 | 22 Feb 2026 | ₹1,50,000 | ₹27,000 | Left as Pending | ₹27,000 Lapsed permanently |
| INV-955 | 18 Mar 2026 | ₹1,00,000 | ₹18,000 | Changed to Accept | ₹18,000 Claimed in 2B |
The total tax credit at risk was ₹36,000 + ₹27,000 + ₹18,000 = ₹81,000. By accepting INV-841 and INV-955, Shiva Traders saved ₹54,000 of input tax credit. Because INV-902 was left pending past 30 November 2026, the credit of ₹27,000 was lost permanently under Section 16(4).
Frequently asked questions
What happens if an invoice of FY 2025-26 remains pending on IMS past 30 November 2026?
Under Section 16(4) of the CGST Act, the deadline to claim input tax credit for FY 2025-26 expires on 30 November 2026 or filing the annual return, whichever is earlier. An invoice kept pending does not flow into GSTR-2B, so keeping it pending past this cut-off causes the ITC to lapse permanently.
What happens if no action is taken on an invoice in the IMS dashboard?
Under the Invoice Management System, where no action is taken by the recipient on an inward supply record filed by the supplier, the record is treated as deemed accepted at the time of GSTR-2B generation on the 14th of the month.
Does an amended invoice reset my earlier action in IMS?
Yes. When a supplier files an amendment to an invoice via Form GSTR-1A or a subsequent Form GSTR-1, the amended record flows into the recipient IMS dashboard as a fresh document, resetting any previous action.
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Last checked: 27 October 2026. Sources: CBIC Tax Information Portal, GSTN Additional FAQs on IMS.