GST Council in its 42nd meeting held on 05.10.2020, had recommended that registered person having aggregate turnover up to 5 crore (five crore) rupees may be allowed to furnish return on quarterly basis along with monthly payment of tax, with effect from 01.01.2021.
Who is eligible 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. This new Scheme will be effective from 01.01.2021.
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. 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.
How to exercise Option for QRMP Scheme?
Facility to avail the Scheme on the common portal would be available throughout the year. a registered person can opt in for any quarter from first day of second month of preceding quarter to the last day of the first month of the quarter. In order to exercise this option, the registered person must have furnished the last return, as due on the date of exercising such option.
For example: A registered person intending to avail of the Scheme for the quarter ‘July to September’ can exercise his option during 1st of May to 31st of July.
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). If the taxpayer opts to 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 he is exercising his option on 27th July for the quarter (July to September), in such case, he must have furnished the return for the month of June which was due on 22/24th July.
Deemed monthly/quarterly filing of GSTR-3B
For the first quarter of the Scheme i.e. for the quarter January, 2021 to March, 2021, in order to facilitate the taxpayers, it has been decided that all the registered persons, whose aggregate turnover for the FY 2019-20 is up to 5 crore rupees and who have furnished the return in FORM GSTR-3B for the month of October, 2020 by 30th November, 2020, shall be migrated on the common portal as below.
Therefore, taxpayers are advised to furnish the return of October, 2020 in time so as to be eligible for default migration. The taxpayers who have not filed their return for October, 2020 on or before 30th November, 2020 will not be migrated to the Scheme. They will be able to opt for the Scheme once the FORM GSTR-3B as due on the date of exercising option has been filed.
|Sr. No||Class of registered person||Default Option|
|1||Registered persons having aggregate turnover of up to 1.5 crore rupees who have furnished FORM GSTR-1 on quarterly basis in the current financial year||Quarterly return|
|2||Registered persons having aggregate turnover of up to 1.5 crore rupees who have furnished FORM GSTR-1 on monthly basis in the current financial year||Monthly Return|
|3||Registered persons having aggregate turnover more than 1.5 crore rupees and up to 5 crore rupees in the preceding financial year.||Quarterly return|
However, such registered persons are free to change the option as above, if they so desire, from 5th of December, 2020 to 31st of 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:
- IFF (Invoice Furnishing Facility) is available between the 1st day of the succeeding month till the 13th day of the succeeding month. after 13th of the month, this facility for furnishing IFF for previous month would not be available.
- 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 01.01.2021.
It is re-iterated that said facility is not mandatory and is only an optional facility made available to the registered persons under the 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. The taxpayers can pay their monthly tax liability either in the
1. Fixed Sum Method (FSM), also popular as 35% challan method, or
2.Self 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.
|Sr 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:
1: If GSTR-3B for January 2021 to March 2021 was filed on a quarterly basis
|Tax paid in cash in Quarter(January-March,2021||Tax Required to be paid in each of the Months-April and May,2021|
2: If GSTR-3 was filed on a monthly basis during the quarter of January 2021 to March 2021
|Tax paid in cash in March,2021||Tax Required to be paid in each of the Months-April and May,2021|
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 GST PMT-06.
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
|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
Fixed Sum Method (FSM) or popularly known as the 35% challan method
|Sr 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 quarter 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 @ 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), 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 every day of delay||Late fee for every day of delay (in case of ‘Nil’ tax liability)|
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.