Quarterly
Return Filing and Monthly Payment of Taxes (QRMP) Scheme under GST
The
Central Board of Indirect Taxes & Customs (CBIC) introduced Quarterly
Return Filing and Monthly Payment of Taxes (QRMP) scheme under Goods and
Services Tax (GST) to help small taxpayers whose turnover is less than Rs.5
crores. The QRMP scheme allows the taxpayers to file GSTR-3B on a quarterly
basis and pay tax every month.
Latest
Updates on QRMP scheme
28th
May 2021
At the 43rd GST Council meeting, the following was announced:
(1) The time limit to furnish B2B supplies on the IFF (optional facility for
the taxpayers opting into the QRMP scheme), for May 2021 has been extended from
13th June to 28th June 2021.
(2) For any delayed submission of PMT-06 for April 2021 and May 2021, interest
relief has been provided as follows:
(i) For April 2021, No interest is charged for delayed submission up to 9th
June, whereas 9% of reduced interest is charged between 10th June and 9th July,
and 18% of interest is charged thereafter.
(ii) For May 2021, No interest is charged for delayed submission up to 10th
July, whereas 9% of reduced interest is charged between 11th and 25th July, and
18% of interest is charged thereafter.
(3) Quarterly GSTR-3B filing for Jan-Mar 2021 has also got interest and late
fee relief as laid down here.
1st May 2021
The time limit to furnish B2B supplies on the IFF (optional facility for the
taxpayers opting into the QRMP scheme), for April 2021 has been extended from
13th May to 28th May 2021.
6th January 2021
IFF is LIVE on GST portal. Sorting out the B2B documents for IFF reporting
becomes essential to pass tax credits to buyers but may get cumbersome. The
GSTN’s advisory stated that the option to upload details in IFF can be used
till 13th of the next month. Any invoices left out to be reported can be filed
using the IFF in the consequent month IFF or directly on the quarterly Form
GSTR-1.
Navigate to Returns > Services > Returns Dashboard > File Returns >
Select FY and month > click on the ‘SEARCH’ button to file the IFF forms.
December 2020
The last date to opt in or out of the QRMP scheme for small GST taxpayers is
31st January 2021 for the quarter of Jan-Mar 2021.
Who
is eligible for the QRMP scheme?
A
registered person who is required to furnish a return in GSTR-3B, and who has
an aggregate turnover of up to Rs.5 crore in the preceding financial year, is
eligible for the QRMP Scheme. Further, in case the aggregate turnover exceeds
Rs.5 crore during any quarter in the current financial year, the registered
person shall not be eligible for the scheme from the next quarter.
It
is clarified that the aggregate annual turnover for the preceding financial
year shall be calculated in the common portal taking into account the details
furnished in the returns by the taxpayer for the tax periods in the preceding
financial year.
The
quarterly GSTR-3B filing option was made available from 1st January 2021
onwards. It is clarified that this scheme is optional and can be availed based
on GSTIN.
How
to exercise Option for QRMP Scheme?
A
registered person who intends to file his GSTR-3B quarterly should indicate the
same on the GST portal, from the 1st of the second month of the preceding
quarter until the last day of the first month of the quarter for which such
option is being exercised.
For
example: If A wishes to file quarterly returns for the quarter of Apr-Jun 2021,
he should have opted for quarterly filing on the common GST portal between 1st
February 2021 and 30th April 2021.
Once
the registered person has opted for quarterly filing, he will have to continue
to furnish his return every quarter for all future tax periods, except in the
following situations:
If
the taxpayer becomes ineligible for furnishing a quarterly return (for example,
if the aggregate turnover crosses Rs.5 crore during a quarter, then from the
next quarter he will not be able to file quarterly returns). In such a case,
the taxpayer must furnish GSTR-3B on a monthly basis.
A
registered person will not be eligible to opt for furnishing quarterly returns
if the last return, which was due on the date of exercising such an option, has
not been furnished.
For
example, if the person is opting for quarterly GSTR-3B filing on 1st December
2020, he will need to furnish his GSTR-3B return for October 2020, which would
have been the last return due on the date of exercising the quarterly filing
option.
Deemed
monthly/quarterly filing of GSTR-3B
The
taxpayer has to follow the above procedure to opt for the quarterly GSTR-3B.
However, in case of registered persons falling in the categories specified in
the table below, who have furnished their GSTR-3B return for October 2020 by
30th November 2020, it shall be deemed that they have opted for monthly or
quarterly filing as detailed below-
|
S
No.
|
Class
of Registered Persons
|
Deemed
Option
|
|
1
|
Registered
individuals with an aggregate turnover of up to Rs.1.5 crore, who have
furnished Form GSTR-1 quarterly in the current financial year
|
Quarterly
GSTR-3B
|
|
2
|
Registered
persons with an aggregate turnover of up to Rs.1.5 crore, who have furnished
Form GSTR-1 monthly in the current financial year
|
Monthly
GSTR-3B
|
|
3
|
Registered
persons having an aggregate turnover exceeding Rs.1.5 crore and up to Rs.5
crore in the preceding financial year
|
Quarterly
GSTR-3B
|
The
taxpayers referred to in the Sl. No. 2 in the above table could have changed
the default option and opt for quarterly GSTR-3B filing between 5th December
2020 and 31st January 2021.
How
to submit details of outward supplies?
The
taxpayers who opted for the QRMP scheme can use the Invoice
Furnishing Facility(IFF) which allows quarterly GSTR-1 filers to upload
their invoices every month. One should keep the following points in mind before
utilising the IFF:
The
IFF can be utilised only for the first two months of a quarter.
The
invoices relating to the last month of a quarter are to be uploaded in the
GSTR-1 return only.
There
is no requirement to upload invoices in GSTR-1 if the same has been uploaded in
the IFF.
The
taxpayer has to submit the B2B invoice details of sale transactions (both
inter-state and intra-state) along with debit and credit notes of the B2B
invoices issued during the month.
The
total net value of invoices that can be uploaded is restricted to Rs.50 lakh
per month.
The
details submitted in IFF will be reflected in the GSTR-2A, GSTR-2B, GSTR-4A or
GSTR-6A of the recipients as the case may be.
The
Invoice Furnishing Facility will come into effect from 1st January 2021.
How
to make monthly tax payments under the QRMP scheme?
The
taxpayer has to deposit tax using form PMT-06 by the 25th of the following
month, for the first and second months of the quarter. The taxpayers can pay
their monthly tax liability either in the Fixed Sum Method (FSM), also popular
as 35% challan method, or use the Assessment Method (SAM).
Fixed
Sum Method (FSM) or 35% challan method:
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.
|
S
No
|
Type
of Taxpayer
|
Tax
to be paid
|
|
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
|
Example
for understanding FSM:
Scenario
1: If GSTR-3B for January 2021 to March 2021 was filed on a quarterly
basis
|
Tax
paid in cash during Jan’21 – Mar’21 quarter
|
|
Tax
required to be paid in each of Apr’21 and May’21
|
|
CGST
|
10,000
|
|
CGST
|
3,500
|
|
SGST
|
10,000
|
|
SGST
|
3,500
|
|
IGST
|
20,000
|
|
IGST
|
7,000
|
|
Cess
|
3,000
|
|
Cess
|
1,050
|
Scenario
2: If GSTR-3 was filed on a monthly basis during the quarter of January
2021 to March 2021
|
Tax
paid in cash during Mar’21
|
|
Tax
required to be paid in each of Apr’21 and May’21
|
|
CGST
|
3,000
|
|
CGST
|
3,000
|
|
SGST
|
3,000
|
|
SGST
|
3,000
|
|
IGST
|
5,000
|
|
IGST
|
5,000
|
|
Cess
|
1,000
|
|
Cess
|
1,000
|
Self
Assessment Method (SAM):
This
is the existing method where a taxpayer can pay the tax liability by
considering the tax liability on inward and outward supplies and the input tax
credit available. The taxpayer has to manually arrive at the tax liability for
the month and has to pay the same in form PMT-06. For ascertaining the amount
of ITC available for the month the taxpayer can use form GSTR-2B.
There
are certain instances where no amount may be required to be deposited, such as–
For
the first month of the quarter – where the balance in the electronic
cash/credit ledger is adequate for the tax liability of the said month OR where
the tax liability is nil.
For
the second month of the quarter – where the balance in the electronic
cash/credit ledger is adequate for the cumulative tax liability for the first
and second months of the quarter OR where the tax liability is nil.
It
is to be noted that a registered person will not be eligible for the said
procedures unless he has furnished the return for the complete tax period
preceding such month. A complete tax period is a tax period where the said
person is registered from the first until the last day of the tax period.
Due
dates for filing quarterly GSTR-3B
The
due dates filing quarterly GSTR-3B has been notified as follows:
|
S
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
|
Input
Tax Credit Claims under QRMP Scheme
There
is no procedural difference in the way Input Tax Credit (ITC) is claimed by a
registered person opting into the QRMP scheme. The QRMP taxpayers who are using
the self-assessment method of calculating the tax payments for the first two
months of the quarter can consider the ITC available as per their GSTR-2B for
the month. Accordingly, they can pay the balance as cash towards the GST
liability.
However,
the GSTR-2B for the quarter gets generated on 14th of the month following the
quarter upon the filing of quarterly GSTR-1. Hence, the buyers who deal with
the vendors under the QRMP scheme will need to refer to quarterly GSTR-2B for
ITC claims.
Interest
under QRMP scheme
The
interest will be applicable as follows if the taxpayer opts for one of the
following methods:
Fixed
Sum Method (FSM) or popularly known as the 35% challan method:
|
S
No
|
Scenario
|
Interest
to be paid
|
|
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 quarters based on the state of the
taxpayer.
The
interest will be applicable as follows if the taxpayer opts for Self
Assessment Method (SAM):
The
taxpayer has to pay interest at 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 at18% if there is
any late payment of tax in the third month of a quarter. This is applicable
irrespective of Fixed Sum Method (FSM), popular as 35% challan method, 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 the Act
|
Late
fee for everyday of delay
|
Late
fee for everyday of delay(in case of ‘Nil’tax liability)
|
|
CGST
Act
|
Rs.25
|
Rs.10
|
|
SGST
Act
|
Rs.25
|
Rs.10
|
|
IGST
Act
|
Rs.50
|
Rs.20
|
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 PMT-06.
Issues
or Challenges under QRMP
Whether
to opt into QRMP or to continue with monthly returns must be decided for each
of the GSTINs of a business (PAN), which can be tedious and time consuming. The
segregation of the documents as B2B and non-B2B must also be done where the
taxpayer opting into the scheme uses the Invoice Furnishing Facility
(IFF).
It
would help in moving the B2B documents to IFF and rest directly to the
quarterly GSTR-1 return. Moreover, the reconciliation between IFF, sales
register and GSTR-1 becomes more essential. Further, the taxpayer under QRMP
scheme must choose between two methods for tax payment every month, i.e. Fixed
Sum/35% challan Method and Self-assessment Method.
