Quarterly Return Monthly Payment Scheme (QRMP Scheme)
1. What is QRMP Scheme?
Currently, a registered person having aggregate turnover of up to ₹5 crores and furnishing GSTR 1 on monthly/quarterly basis, files GSTR 3B on monthly basis only. Under QRMP scheme, such registered persons shall be required to furnish GSTR 3B too on quarterly basis but with monthly payment of net cash liability.
| Regular Scheme | QRMP Scheme |
| GSTR 3B – Monthly
GSTR 1 – Quarterly |
GSTR 3B – Quarterly
GSTR 1 – Quarterly |
2. How to pay tax on monthly basis under QRMP Scheme?
Net cash liability for every month shall be discharged by using PMT-06 challan. There are two ways to pay tax on monthly basis under QRMP scheme.
| MONTH | Fixed Sum Method | Self-Assessment Method |
| 1st month | 35% of total cash paid in previous quarter’s GSTR 3B OR (in case of first quarter) 100% of total cash paid in last monthly GSTR 3B | Actual Basis |
| 2nd month | 35% of total cash paid in previous quarter’s GSTR 3B OR (in case of first quarter) 100% of total cash paid in last monthly GSTR 3B | Actual Basis |
| 3rd month | As per actual liability for the quarter reduced by cash paid during first two months | As per actual liability for the quarter reduced by cash paid during first two months |
3. What about cash that remains unutilized after filing of quarterly GSTR 3B?
In case, any cash gets reflected in Electronic Cash Ledger after filing of GSTR 3B for the relevant quarter, the same can be utilized for future liability. It should be noted that cash deposited via PMT-06 for any month cannot be utilized for any other purpose before filing of GSTR 3B for the relevant quarter.
4. In case payment is made monthly by fixed sum method, what if there is no cash liability in previous quarter?
In that case, the tax liability for the first two months to be paid via PMT-06 shall be Nil.
5. What is the due date of paying net cash liability by PMT-06?
Due date for paying net cash liability is 25th of next month for the first two months. For the third month, cash payment, if any, shall be made in GSTR 3B, so the due date shall be 22nd/24th of the next month.
| Due Date | Payment of cash liability |
| 1st
month |
25th of next month |
| 2nd
month |
25th of next month |
| 3rd month | 22nd / 24th of next month |
6. What is Invoice Furnishing Facility or IFF?
Since availment of ITC has been made more dependent on GSTR 2B, quarterly tax payers may be required to furnish document details monthly for their recipients who file their returns monthly. This is where IFF comes in. IFF is nothing but a facility similar to GSTR 1 whereby a registered person, opting for QRMP scheme, can upload details of documents such as invoices, credit/debit notes, amendments etc. on monthly basis. Such details uploaded in IFF shall not be required to be furnished again in Quarterly GSTR 1. However, GSTR 1 shall be filed with non-uploaded details, if any.
7. What about Late Fees and Interest on non-payment of PMT-06 and non-filing of GSTR 3B?
No late fee shall be applicable on late filing of PMT-06 for the first two months. However, late fee shall be applicable on late filing of GSTR 3B for the relevant quarter. On the other hand, interest shall be applicable on late discharge of net cash liability via PMT-06 as well as quarterly GSTR 3B. Please refer below for detailed analysis:
|
MONTH |
Fixed Sum Method |
Self-Assessment Method |
||
|
Within due date |
After due date | Within due date |
After due date |
|
| 1st month | No interest | Interest @ 18% from due date till actual payment | If liability is short paid, interest @ 18% from due date till actual payment | Interest @ 18% from due date till actual payment |
| No late fee | No late fee | No late fee | No late fee | |
| 2nd month | No interest | Interest @ 18% from due date till actual payment | If liability is short paid, interest @ 18% from due date till actual payment | Interest @ 18% from due date till actual payment |
| No late fee | No late fee | No late fee | No late fee | |
|
3rd month |
No interest | Interest @ 18% from due date till actual payment | No interest | Interest @ 18% from due date till actual payment |
| No late fee | Late fee @ ₹50/20 per day from due date till actual payment | No late fee |
Late fee @ ₹50/20 per day from due date till actual payment |
|
Thus, for registered person making payment of tax by opting Self-Assessment Method, even though the net cash liability has been discharged within the relevant due date, interest amount would still be payable as per the provisions of Section 50 of the CGST Act (18%) 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. The same is not applicable on payment of tax by Fixed Sum Method since the payment is made based on net cash liability of previous quarter.
Example – For January 2021, GST of ₹5000 is paid on 20th February, 2021 under QRMP scheme via PMT-06. However, later on 20th March, 2021 it is discovered that the actual net cash liability for the month of January 2021 was ₹8000. Thus, there can be two scenarios in this situation:
- If net cash payment was made by fixed sum method, no interest shall be applicable on short payment of ₹3000.
- If net cash payment was made by self-assessment method, interest @18% shall be applicable on ₹3000 from 26th February, 2021 till 20th March, 2021.
8. How and when to opt-in or opt-out of QRMP Scheme?
A registered normal taxpayer can opt-in or opt-out for QRMP scheme on quarterly basis from Services tab in GST Portal. However, it is not necessary to manually opt-in for every quarter. The opt-in choice, once exercised, shall continue by default unless the taxpayer opts-out manually. Time period for exercising opt-in for a quarter shall be from 1st day of the second month of the previous quarter till the last day of the first month of the given/relevant quarter.
Example – For the quarter April-June, 2021, opt-in can be exercised from 1st February, 2021 till 30th April, 2021.
9. Is it necessary to pay cash via PMT-06 if there is already enough cash in electronic credit ledger?
No. No cash payment is necessary if the existing balance in the electronic cash ledger is adequate for the net cash liability of the first month or cumulative net cash liability of the first and second months, as the case may be.
10. What are the pros and cons of the QRMP scheme?
| QRMP Scheme | |
| PROS | CONS |
| IFF facility under QRMP scheme allows uploading of document details even though GSTR 1 is to be filed quarterly. This plugs in the gap where the supplier files GSTR 1 quarterly and the recipient requires the ITC monthly. | Necessity to keep track of details mentioned in IFF for the first two months of the quarter during the filing the quarterly GSTR 1. |
| Easier payment of net cash liability under fixed sum method. | If fixed sum method is followed for cash payment, there can be scenarios wherein relevant quarter’s cash liability is considerably lesser than the previous quarter’s net cash payment. In such scenarios, excess cash may remain deposited and this will lead to blocking of taxpayer’s working capital. |
| No late fee for filing of PMT-06 after due date as against late fee levied for filing of monthly GSTR 3B after due date under regular scheme. | If self-assessment method is followed for cash payment, it makes no difference. The working and calculations required to be done under QRMP scheme shall be the same as done in regular scheme. Moreover, there shall arise liability of interest if net cash payment turns out to be short-paid. |
Disclaimer: The analysis done and views expressed in this article are based on my personal knowledge and understanding of the topic and I do not assume responsibility or liability for accuracy thereof.
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