QRMP Scheme : FAQs on quarterly filing of GSTR-3B & monthly GST payment

Ans: Currently the periodicity of filing GSTR-3B return along with payment of GST is monthly. Under QRMP Scheme, in order to facilitate small tax payers they will be allowed to file GSTR-3B return on quarterly basis, however payment of GST will be required to be made on monthly basis.

This new Scheme will be effective from 01.01.2021 and it is an optional scheme. The eligible tax payers can opt for the scheme or may also not opt it and continue with the normal monthly filing of GSTR-3B.

Ans: 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.

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.

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.

Ans: Facility to avail the Scheme on the common portal would be available throughout the year. In terms of rule 61A of the CGST Rules, 2017, 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.

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.

Ans: Registered persons are not required to exercise the option every quarter. 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.

Ans: For the first quarter of the Scheme i.e. for the quarter January, 2021 to March, 2021, in order to facilitate the taxpayers, all the registered persons, whose aggregate turnover for the FY 2019-20 is up to Rs 5 crore 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:

1. For Registered persons having aggregate turnover of up to Rs 1.5 crore who have furnished GSTR-1 on quarterly basis in the current financial year default option will be quarterly return.

2. For Registered persons having aggregate turnover of up to Rs 1.5 crore who have furnished GSTR-1 on monthly basis in the current financial year default option will be monthly return.

3. For Registered persons having aggregate turnover more than Rs 1.5 crore and up to Rs 5 crore in the preceding financial year default option will be monthly return.

It may be noted here that Registered persons are free to change the default option as above, if they so desire, from 05.12.2020 to 31.01.2021.

If you want default migration as above you should ensure that you furnish GSTR-3B of October, 2020 positively by 30.11.2020, else you will not be migrated to the Scheme and you will be able to opt for the Scheme once the FORM GSTR-3B as due on the date of exercising option has been filed.

Ans: The facility for opting out of the Scheme for a quarter will be available from first day of second month of preceding quarter to the last day of the first month of the quarter.

Example: A registered person intending to opt out of the Scheme for the quarter ‘April to June’ can exercise opting out during period 1st of February to 30th of April.

Ans: Any registered person, whose aggregate turnover crosses Rs 5 crore during a quarter in current financial year, shall opt for furnishing of return on a monthly basis, electronically, on the common portal, from the succeeding quarter. In other words, 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 QRMP Scheme from the next quarter.

Ans: The option to avail the QRMP Scheme is GSTIN wise and therefore, distinct persons as defined in Section 25 of the CGST Act (different GSTINs on same PAN) have the option to avail the QRMP Scheme for one or more GSTINs. In other words, some GSTINs for that PAN can opt for the QRMP Scheme and remaining GSTINs may not opt for the Scheme.

Ans: Yes, 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 Rules.

Ans: For each of the first and second months of a quarter, the registered person who has opted for QRMP scheme 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 Rs 50 lakhs 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.

 For example, 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 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.

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.

Also Read: Taxpayers under QRMP Scheme can file quarterly GSTR-1 without filing IFF : CBIC

Ans: 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 25^th of the succeeding month.

While generating the challan, taxpayers should select “Monthly payment for quarterly taxpayer” as reason for generating the challan.

There are two options viz fixed sum method and self-assessment method, for monthly payment of tax during the first two months of a quarter.

Ans: There are two options for monthly payment of tax during the first two months which are discussed below:

(a) Fixed Sum Method: A facility is being made available on the portal for generating a pre-filled challan in FORM GST PMT-06. The challan will be generated for following amount:

Situation I: Where tax payer had filed GSTR-3B of previous quarter on quarterly basis.
35% of tax paid (CGST / SGST/ IGST/ UTGST/ Cess) in cash will be required to be paid in first two months of the quarter.

Situation II. Where tax payer had filed GSTR-3B of previous quarter on monthly basis.
Tax required to be paid in first two quarters will be equal to the tax paid in cash in the last month of the immediately preceding quarter.

It may be noted here that the quarter Jan – March, 2021 will be first quarter of the scheme and as GSTR-3B for the period till December,2020 will have been filed on monthly basis, thus the taxpayer opting for fixed sum method will be governed under Situation II above and he will have to pay the amount of tax equal to tax paid in December,2020.
It may be noted that monthly tax payment through this method would not be available to those registered persons who have not furnished the return for a complete tax period preceding such month. A complete tax period means a tax period in which the person is registered from the first day of the tax period till the last day of the tax period.

(b) Self-Assessment Method: The persons can also 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.

The registered person is free to avail either of the two tax payment methods in any of the two months of the quarter.

Ans: No, In case the balance in the electronic cash ledger and/or electronic credit ledger is adequate for the tax due for the first month of the quarter or where there is nil tax liability, the registered person may not deposit any amount for the said month. Similarly, for the second month of the quarter, in case the balance in the electronic cash ledger and/or electronic credit ledger is adequate for the cumulative tax due for the first and the second month of the quarter or where there is nil tax liability, the registered person may not deposit any amount.

Ans: Any claim of refund in respect of the amount deposited for the first two months of a quarter for payment of tax shall be permitted only after the return in FORM GSTR-3B for the said quarter has been furnished. Further, this deposit cannot be used by the taxpayer for any other purpose till the filing of return for the quarter.

Ans: The registered persons opting for QRMP scheme would be required to furnish FORM GSTR-3B, for each quarter, on or before 22nd / 24th day of the month succeeding such quarter (based on State / UT where its place of business is located).

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.

Ans: In case of cancellation of registration of a person who had opted for QRMP scheme, 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.

Ans: 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 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.

As discussed earlier the due date of payment of challan in first two months is 25^th of next month and that of GSTR-3B for the quarter is 22^nd / 24^th of the next month. Thus if payment of taxes is made by above dates, no interest will be payable.

If system generated challans not paid by 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.

If GSTR-3B for the quarter is filed after due date
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.

Illustration:
A registered person, who has opted for the Scheme, had paid a total amount of Rs. 100/- in cash as tax liability in the previous quarter of October to December.

Situation I: Monthly payment of tax and GSTR-3B is filed by due dates
In above case if the person has deposited challan for fixed sum for first two months by 25th February and 25th March and also discharged entire tax liability for the quarter in GSTR-3B by due date i.e. 22^nd / 24^th April,2020, no interest will be applicable on amount of shortfall is payment of tax in the first two months.


Situation II: If GSTR-3B is filed late
In his GSTR-3B for the quarter, it is found that total liability for the quarter net of available credit was Rs 120/- for CGST and SGST each and Rs 200 for IGST. Suppose he filed its GSTR-3B on 30th April instead of due date of 24^th April.

In such a case Interest would be payable @ 18% p.a. on Rs. 50 for CGST and SGST each [Rs. 120 – Rs. 70 (deposit made in cash ledger in first two months)] and Rs 88 for IGST [Rs. 200 – Rs. 112 (deposit made in cash ledger in first two months)] for the period of 6 days i.e. form 24^th April to 30^th April.

Situation III: Monthly payment of tax is not on time
In this case interest would be payable @ 18% p.a., from the due date of furnishing FORM GST PMT-06 till the date of making such payment

Thus if payment for the month of January is made on 28^th February, interest need to be paid on Rs 35/- for CGST and SGST and Rs 56 for IGST for a period of 3 days [due date of payment i.e. 25^th Feb to date of payment i.e. 28^th February].

Ans: 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.

Thus in self-assessment case the person will be required to pay interest in case any shortfall arises in payment of tax in the first two months of the quarter.

 Ans: Interest payable, if any, shall be paid through FORM GSTR-3B.

Ans: 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.

Accordingly no late fee is applicable for delay in payment of tax in first two months of the quarter. However late fee of Rs 200/- per day (CGST + SGST) subject to maximum of Rs 10,000/- (CGST + SGST) will be applicable in case the quarterly GSTR-3B is not filed by due date i.e. 22^nd / 24^th of month succeeding the quarter.