The Central Board of Indirect Taxes & Customs (CBIC) has introduced the Quarterly Return Filing and Monthly Payment of Taxes (QRMP) scheme which states that under Goods and Services Tax (GST), a registered person whose turnover is less than 5 crore rupees is allowed to file GSTR 3B on a Quarterly basis but has to make the payment on a monthly basis.
Eligibility for the QRMP scheme
A registered person who is required to furnish a return in FORM GSTR-3B, and who has an aggregate turnover of up to 5 crore rupees in the preceding financial year, is eligible for the QRMP Scheme. Further, in case the aggregate turnover exceeds 5 crore rupees during any quarter in the current financial year, the registered person shall not be eligible for the scheme from the next quarter. This scheme is optional and can be availed based on GSTIN.
How to submit details of outward supplies?
With the scheme of QRMP Invoice Furnishing Facility is also available so that outward B2B supply can be entered to the portal on monthly basis.
Invoice Furnishing Facility for taxpayers who have opted for QRMP scheme to declare outward supplies to a registered person for first two months of any quarter. It is an optional facility which is similar to Form GSTR-1. It allows filing for only B2B invoices, credit notes, debit notes etc. The last date of filing IFF for a month is the 13th of the following month. This will allow recipient taxpayers to take credit of these invoices in the same month, if reported in IFF, by the supplier taxpayer under QRMP scheme.
How to make monthly tax payments under the QRMP scheme?
The taxpayer has to deposit tax using form GST PMT-06 by the 25th of the following month, for the first and second months of the quarter. There are two methods of paying monthly tax liability :
- Fixed Sum Method (FSM) or
- Self Assessment Method (SAM).
( i) Fixed Sum Method (FSM):
The taxpayer must pay an amount of tax mentioned in a pre-filled challan in the form GST PMT-06 for an amount equal to 35% of the tax paid in cash.
Sr. No |
Type of Taxpayer |
Tax |
|||||||
1 |
Who furnished GSTR-3B quarterly for the last quarter |
35% of tax paid in cash in the preceding quarter |
|||||||
2 |
Who furnished GSTR-3B monthly during the last quarter |
100% of tax paid in cash in the last month of the immediately preceding quarter |
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Example of FSM |
|||||||||
Situation 1 |
Situation 2 |
||||||||
If GSTR-3B for January 2021 to March 2021 was filed on a quarterly basis |
If GSTR-3 was filed on a monthly basis during the quarter of January 2021 to March 2021 |
||||||||
Tax paid in cash during Jan’21 - Mar’21 quarter |
Tax required to be paid in each of Apr’21 and May’21 |
Tax paid in cash during Mar’21 |
Tax required to be paid in each of Apr’21 and May’21 |
||||||
CGST |
5000 |
CGST |
1750 |
CGST |
2000 |
CGST |
2000 |
||
SGST |
5000 |
SGST |
1750 |
SGST |
2000 |
SGST |
2000 |
||
IGST |
10000 |
IGST |
3500 |
IGST |
4000 |
IGST |
4000 |
||
CESS |
2000 |
CESS |
700 |
CESS |
1000 |
CESS |
1000 |
||
(ii) Self Assessment Method (SAM):
This is the prevailing method where a taxpayer can pay the tax liability by considering the tax inward and outward supplies and the input tax credit available. The taxpayer has to physically arrive at the tax liability for the month and has to pay the same in form GST PMT-06. For the amount of ITC available for the month the taxpayer can use form GSTR-2B .
There are certain cases where no amount may be required to be deposited, such as -
(a) For the first month of the quarter - where the balance in the electronic cash/credit ledger is sufficient for the tax liability of the said month OR where the tax liability is nil.
(b) For the second month of the quarter - where the balance in the electronic cash/credit ledger is sufficient for the cumulative tax liability for the first and second months of the quarter OR where the tax liability is nil.
Due dates for filing quarterly GSTR-3B
The due dates filing quarterly GSTR-3B has been notified as follows:
Sr No |
GST Registration in States and Union Territories |
Due Date |
1 |
Chhattisgarh, Madhya Pradesh, Gujarat, Dadra and Nagar Haveli, Daman and Diu, Maharashtra, Karnataka, Goa, Lakshadweep, Kerala, Tamil Nadu, Puducherry, Andaman and Nicobar Islands, Telangana and Andhra Pradesh |
22nd of the month succeeding such quarter |
2 |
Jammu and Kashmir, Ladakh, Himachal Pradesh, Punjab, Chandigarh, Uttarakhand, Haryana, Delhi, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Mizoram, Manipur, Tripura, Meghalaya, Assam, West Bengal, Jharkhand and Odisha |
24th of the month succeeding such quarter |
Interest under QRMP scheme
The interest will be applicable as follows if the taxpayer opts for Fixed Sum Method (FSM):
Sr. No |
Situation |
Interest |
1 |
Tax liability mentioned in pre-filled form GST PMT-06 is paid by 25th of the following month. |
Nil |
2 |
Tax liability mentioned in pre-filled form GST PMT-06 is not paid by 25th of the following month. |
18% of the tax liability (from 26th of the following month till the date of payment) |
3 |
The final tax liability for the first two months is less than or equal to the amount paid through pre-filled form GST PMT-06. |
Nil |
4 |
The final tax liability for the first two months is higher than the tax amount paid through pre-filled form GST PMT-06, and such excess liability has been paid within quarterly GSTR-3B due date. |
Nil |
5 |
The final tax liability for the first two months is higher than the tax amount paid through pre-filled form GST PMT-06, and such excess liability has not been paid within quarterly GSTR-3B due date. |
18% of the tax liability (from GSTR-3B due date* till the date of payment) |
*22nd or 24th of the month succeeding such quarter based on the state of the taxpayer.
Interest under Self Assessment Method (SAM)
The taxpayer has to pay interest @ 18% on the net tax liability which remains unpaid or paid beyond the due date for the first two months of the quarter.
It is important to note that the taxpayer has to pay interest @18% if there is any late payment of tax in the third month of a quarter. This is applicable irrespective of Fixed Sum Method (FSM) or Self Assessment Method (SAM).
Late fee under QRMP scheme
The late fee should be paid as follows if the quarterly GSTR-3B is not filed within due date, subject to a maximum late fees of Rs 5,000:
Name of Act |
Late Fee |
|
NIL Tax Liability (Rs.) |
OTHERS (Rs.) |
|
CGST |
10 |
25 |
SGST |
10 |
25 |
IGST |
20 |
50 |
However, it is clarified that no late fee is applicable for delay in payment of tax in the first two months of the quarter in form GST PMT-06.
When can a Taxpayer opt out the QRMP Scheme?
Taxpayer can opt in or opt out of the QRMP scheme any time during the year as per the timelines mentioned in the table below:
S No |
Quarter of a particular year |
QRMP Scheme can be opted in or opted out during |
1. |
Q1 (April - May - June) |
1st February to 30th April |
2. |
Q2 (July - August - September) |
1st May to 31st July |
3. |
Q3 (October - November - December) |
1st August to 31st October |
4. |
Q4 (January - February - March) |
1st November to 31st January of the following year |
The author is a member of the Institute of Certified Practising Accountant, Australia and an Associate member of Institute of Chartered Accountants of India and can be reached at casusmitadutta@gmail.com.
Disclaimer: The facts and opinions written in this column are those of the author and have been prepared on the basis of relevant provisions and information available at the time of preparation. The article does not constitute any professional advice or a formal recommendation. The author has undertaken utmost care to disseminate true and correct views and does not accept liability of any errors or omissions.