Quarterly Return Monthly Payment (QRMP) Scheme – GST

Background of Quarterly Return filing & Monthly Payment of Taxes (QRMP) Scheme

The recommendation of 42nd GST Council for registered taxpayers with turnover below Rs 5 Crores may file quarterly return while making payments on a monthly basis. This will be implemented from 1st January, 2020. GST QRMP Scheme

Who is eligible to opt for QRMP?

The registered taxpayer with turnover of Rs 5 Crores and below in the preceding financial year is eligible to opt for QRMP. GST QRMP Scheme

Following registered person (hereinafter ‘RP’) can file quarterly returns and pay tax on monthly basis w.e.f. 01.01.2021 :

  • An registered taxpayer who is required to file Form GSTR 3B with Aggregate Annual Turnover (‘AATO’) of up to Rs 5 Cr. in the previous financial year is eligible. If AATO crosses Rs 5 Cr. during a qtr., registered taxpayer will become in-eligible for the Scheme from next quarter.
  • Any person obtaining a new registration or opting out of Composition Scheme can also opt for this Scheme.
  • The option to avail this Scheme can be availed GSTIN wise. Therefore, few GSTINs for that PAN can opt for the Scheme and remaining GSTINs can remain out of the Scheme.

In terms of notification No. 84/2020- Central Tax, dated 10.11.2020, 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. 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. This new Scheme will be effective from 01.01.2021.

Who is not eligible to opt for QRMP?

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

How to exercise option for QRMP scheme? GST QRMP Scheme

Facility to avail the Scheme on the common portal would be available throughout the year. In terms of rule 61A of the Central Goods and Services Tax Rules, 2017 (hereinafter referred as CGST Rules), 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. 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.

Do we need to opt for QRMP Scheme every quarter?

Registered persons are not required to exercise the option every quarter. Hence, once opt will remain valid for tax period.

Once opted for QRMP Scheme, how long this will remain valid?

Where such option has been exercised once, they shall continue to furnish the return as per the selected option for future tax periods, unless they revise the said option.

What is eligibility for default migration to QRMP Scheme?

Registered taxpayer has to file GSTR-3B for the month of October, 2020 in time in order to be eligible for default migration to QRMP Scheme.

What is changes on the GST Portal?

For quarter January 2021 to March 2021, all registered taxpayers whose Aggregate Annual Turnover (‘AATO’) for the FY 2019-20 is up to Rs 5 Crores and have furnished the return in Form GSTR-3B for the month of October 2020 by 30th November 2020, will be migrated by default in the GST system as follows:

Sl No Taxpayer with Aggregate Annual Turnover Default Return Option
1 Up to Rs 1.5 Cr., who have furnished Form GSTR-1 on quarterly basis in current FY Quarterly
2 Up to Rs 1.5 Cr., who have furnished Form GSTR-1 on monthly basis in current FY Monthly
3 More than Rs 1.5 Cr. and up to Rs 5 Cr. in preceding FY Quarterly
     

When can a person opt for the scheme:

  • Facility can be availed throughout the year, in any quarter.
  • Option for QRMP Scheme, once exercised, will continue till RP revises the option or his AATO exceeds Rs 5 Crores
  • RPs migrated by default can choose to remain out of the scheme by exercising their option from 5th December 2020 till 31st January 2021.

The RPs opting for the scheme can avail the facility of Invoice Furnishing Facility (IFF), so that the outward supplies to registered person is reflected in their Form GSTR 2A & 2B.

Furnishing of details of outward supplies under section 37 of the CGST Act (GST QRMP Scheme)

  • The registered persons opting for the Scheme would be required to furnish the details of outward supply in FORM GSTR-1 quarterly as per the rule 59 of the CGST Rule.
  • For each of the first and second months of a quarter, such a registered person will have the facility (Invoice Furnishing Facility- IFF) to furnish the details of such outward supplies to a registered person, as he may consider necessary, between the 1st day of the succeeding month till the 13th day of the succeeding month. The said details of outward supplies shall, however, not exceed the value of fifty lakh rupees in each month. It may be noted that after 13th of the month, this facility for furnishing IFF for previous month would not be available. As a facilitation measure, continuous upload of invoices would also be provided for the registered persons wherein they can save the invoices in IFF from the 1st day of the month till 13th day of the succeeding month. The facility of furnishing details of invoices in IFF has been provided so as to allow details of such supplies to be duly reflected in the FORM GSTR-2A and FORM GSTR-2B of the concerned recipient.

Examples

A registered person who has availed the Scheme wants to declare two invoices out of the total ten invoices issued in the first month of quarter since the recipient of supplies covered by those two invoices desires to avail ITC in that month itself. Details of these two invoices may be furnished using IFF. The details of the remaining 8 invoices shall be furnished in FORM GSTR-1 of the said quarter. The two invoices furnished in IFF shall be reflected in FORM GSTR-2B of the concerned recipient of the first month of the quarter and remaining eight invoices furnished in FORM GSTR-1 shall be reflected in FORM Circular No. 143/13/2020- GST GSTR-2B of the concerned recipient of the last month of the quarter. The said facility would however be available, say for the month of July, from 1st August till 13th August. Similarly, for the month of August, the said facility will be available from 1st September till 13th September. 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.

  • The details of invoices furnished using the said facility in the first two months are not required to be furnished again in FORM GSTR-1. Accordingly, the details of outward supplies made by such a registered person during a quarter shall consist of details of invoices furnished using IFF for each of the first two months and the details of invoices furnished in
  • FORM GSTR-1 for the quarter. At his option, a registered person may choose to furnish the details of outward supplies made during a quarter in FORM GSTR-1 only, without using the IFF.

Payment of tax under the scheme:

  • Taxpayer need to pay tax due in each of first two months (by 25th of next month) in the Quarter, by selecting “Monthly payment for quarterly taxpayer” as reason for generating Challan.
  • Registered taxpayers can either use Fixed Sum Method (pre-filled challan) or Self-Assessment Method (actual tax due), for monthly payment of tax for first two months, after adjusting ITC.
  • No deposit is required for the month, if there is nil tax liability.

Tax deposited for first 02 months can be used for adjusting liability for the qtr. in Form GSTR-3B and can’t be used for any other purpose till the filing of return for the quarter.

Monthly Payment of tax:

The registered person under the QRMP Scheme would be required to pay the tax due in each of the first two months of the quarter by depositing the due amount in FORM GST PMT-06, by the twenty fifth day of the month succeeding such month. While generating the challan, taxpayers should select “Monthly payment for quarterly taxpayer” as reason for generating the challan. The said person can use any of the following two options provided below for monthly payment of tax during the first two months –

  • Fixed Sum Method: A facility is being made available on the portal for generating a pre-filled challan in FORM GST PMT-06 for an amount equal to thirty five per cent. of the tax paid in cash in the preceding quarter where the return was furnished quarterly; or equal to the tax paid in cash in the last month of the immediately preceding quarter where the return was furnished monthly
  • Self-Assessment Method: The said persons, in any case, can pay the tax due by considering the tax liability on inward and outward supplies and the input tax credit available, in FORM GST PMT-06. In order to facilitate ascertainment of the ITC available for the month, an auto-drafted input tax credit statement has been made available in FORM GSTR2B, for every month.

Quarterly filing of FORM GSTR-3B

Such registered persons would be required to furnish FORM GSTR-3B, for each quarter, on or before 22nd or 24th day of the month succeeding such quarter. In FORM GSTR-3B, they shall declare the supplies made during the quarter, ITC availed during the quarter and all other details required to be furnished therein. The amount deposited by the registered person in the first two months shall be debited solely for the purposes of offsetting the liability furnished in that quarter’s FORM GSTR-3B. However, any amount left after filing of that quarter’s FORM GSTR-3B may either be claimed as refund or may be used for any other purpose in subsequent quarters. In case of cancellation of registration of such person during any of the first two months of the quarter, he is still required to furnish return in FORM GSTR-3B for the relevant tax period.

Applicability of Interest

For registered person making payment of tax by opting Fixed Sum Method

  • No interest would be payable in case the tax due is paid in the first two months of the quarter by way of depositing auto-calculated fixed sum amount as detailed in para 6.1(a) above by the due date. In other words, if while furnishing return in FORM GSTR-3B, it is found that in any or both of the first two months of the quarter, the tax liability net of available credit on the supplies made /received was higher than the amount paid in challan, then, no interest would be charged provided they deposit system calculated amount for each of the first two months and discharge their entire liability for the quarter in the FORM GSTR-3B of the quarter by the due date.
  • In case such payment of tax by depositing the system calculated amount in FORM GST PMT-06 is not done by due date, interest would be payable at the applicable rate, from the due date of furnishing FORM GST PMT-06 till the date of making such payment.
  • Further, in case FORM GSTR-3B for the quarter is furnished beyond the due date, interest would be payable as per the provisions of Section 50 of the CGST Act for the tax liability net of ITC.

For registered person making payment of tax by opting Self-Assessment Method

  • Interest amount would be payable as per the provision of Section 50 of the CGST Act for tax or any part thereof (net of ITC) which remains unpaid / paid beyond the due date for the first two months of the quarter. GST QRMP Scheme.
  • Interest payable, if any, shall be paid through FORM GSTR-3B.

Applicability of Late Fee

Late fee is applicable for delay in furnishing of return / details of outward supply as per the provision of Section 47 of the CGST Act. As per the Scheme, the requirement to furnish the return under the proviso to sub-section (1) of Section 39 of the CGST Act is quarterly. Accordingly, late fee would be the applicable for delay in furnishing of the said quarterly return / details of outward supply. It is clarified that no late fee is applicable for delay in payment of tax in first two months of the quarter. GST QRMP Scheme.

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