The scheme aims to reduce compliance burden of small GST taxpayers by allowing quarterly filing GSTR 3B returns for taxpayers instead of the existing monthly frequency. However payment of tax would have to be done monthly. The details are explained below in the article.
Further small taxpayers can currently file quarterly GSTR 1 which shall continue. There would be an added functionality (Invoice Furnishing Facility) provided in order to declare monthly details, if one wants to without filing of GSTR 1.This would enable reflection of invoices in 2A in order to avail ITC.
Who is the scheme for?
The eligibility for the scheme is for taxpayers who fulfill all of the below conditions
- The Annual turnover should be upto Rs 5 crores.
- All GST returns must be filed.
The Turnover would be checked for preceding financial year based on details furnished in the GST Common portal. Further the turnover should not exceed even during the current financial year.
What is the scheme?
GSTR 3B
Quarterly filing of GSTR 3B returns would be allowed on optional basis. The due date for such quarterly returns would be 22nd or 24th of month after the respective quarter ends depending on the state of registration. However the tax would be required to be paid monthly to avoid interest under Sec 50 of the CGST Act, 2017.
| Due Date | States / UT (arranged alphabetically) |
| 22nd of next month | Andaman and Nicobar Islands, Andhra Pradesh, Chhattisgarh, Goa, Gujarat, Karnataka, Kerala, Lakshadweep, Madhya Pradesh, Maharashtra, Puducherry, Tamil Nadu, Telangana, Daman and Diu and Dadra and Nagar Haveli |
| 24th of next month | Arunachal Pradesh, Assam, Bihar, Chandigarh, Delhi, Haryana, Himachal Pradesh, Jammu and Kashmir, Jharkhand, Ladakh, Manipur, Meghalaya, Mizoram, Nagaland, Odisha, Punjab, Rajasthan, Sikkim, Tripura, Uttar Pradesh, Uttarakhand, West Bengal |
The option to file quarterly return for Q4 (Jan-Mar) of 2020-21 would have to be exercised from 5th of December, 2020 to 31st of January, 2021. But to exercise this option all previous GSTR 3B should be filed.
The time limit for availing the quarterly option for subsequent quarters would be the first day of the second month of preceding quarter to the last day of the first month of the quarter. For example for Q2 i.e. July- Sept the time period would be 1st May to 31st July. All previous returns should be filled.
GSTR 1
GSTR 1 filing would continue as per existing rule i.e. Rule 59 of the CGST Rules,2017. The due date would be 13th of the next month
INVOICE FURNISHING FACILITY (IFF)
This is a new facility which is being introduced to allow submitting of Outward Supply Invoice details without filing of GSTR 1(Quarterly) during first 2 months of the Quarter. This would be beneficial to claim ITC, as these invoices would be reflected in GSTR 2A/2B of the recipient. However there is a limit of Rs 50 Lakhs (value of outward supplies) every month.This is to prevent any major revenue leakage.
IFF can be filed from 1st to 13th of the succeeding month only. There would be no option to file after 13th. This is to allow freezing of details in Form 2B
MONTHLY PAYMENT (PMT 06)
Even if returns are to be filed quarterly the government keeping in mind the revenue interest has mandated monthly paying of taxes. For this Form GST PMT 06 is to be filed every month till the 25th of the succeeding month. In simple words the challan used to deposit cash is to be generated and paid. The reason for generating such challan would be “Monthly payment for quarterly taxpayer”
There are 2 ways in which one can compute the amount to be paid. One is the “Fixed Sum Method” while the other is “Self- Assessment Method”.
Fixed Sum Method
Under this method the taxpayer has to pay at least 35% of tax paid in cash during the last month/quarter depending on whether you file monthly/quarterly returns. The words “Tax paid in cash” indicate that tax paid via the Electronic Cash Ledger is to be considered. The ITC part has to be ignored.
Self-Assessment Method
As the name suggests a person can self-calculate his liability for the month net of ITC and pay accordingly in Form GST PMT-06 (GST Challan). GSTR 2B would be available to ascertain the ITC available for the month.
Since payment is made via debiting the Electronic Cash/Credit ledger there would not be any need to deposit cash if the ledgers reflect sufficient balances for discharging the liability.
Further in case of NIL tax liability for the month there would not be any need to pay any challan.
Incase of short payment in any of the 2 months of the quarter, interest would have to be paid as per Sec 50 (i.e.18% or 24 %)
MISC. DETAILS
Late fee would be applicable for delay in filing of returns. Thus there would be no late fee on delayed payment. Also no late fee would be levied on IFF as it cannot be filed after 13th. To read the circular by CBIC for QRMP scheme the link is
https://www.cbic.gov.in/resources//htdocs-cbec/gst/Circular_Refund_143_11_2020.pdf
Dec 12, 2020 - Blog - Anish Burad
