Effective Date: With effect from 1st Jan, 2021 through circular no Circular No. 143/13/2020-GST notified notification no 81/2020, 82/2020, 84/2020, 85/2020 – Central Tax dtd 10.11.2020.
Applicability: All registered assessee having turnover up to INR 5 crores in the preceding financial year. Scheme can be availed GSTIN based, i.e. assessee having multiple registrations under same PAN have option to avail the QRMP scheme for one GSTIN and Regular filing for other registration.
When to opt: Anytime during the year for any quarter. Once availed can continue to be availed until opted out by the taxpayer or assessee become ineligible.
Facility of opting out: 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.
How to opt: If any assessee wishes to avail the QRMP scheme then it should opt for the scheme from 1st day of second month of previous quarter till the end of first month of respective quarter.
For e.g.- If an assessee requires to avail the QRMP scheme for the quarter ending June 2021, then he should opt for the scheme anytime in between 1st of Feb 2021 till 30th of April 2021.
Mandatory conditions of availment:
- Assessee should have furnished the last return on the due date respectively.
- All the previous returns of the assessee have been filed.
- If turnover crosses INR 5cr then the assessee shall opt out of the scheme automatically.
Filing Structure:
- Under this scheme assessee should file its returns (GSTR 3b and GSTR 1) on quarterly basis on 22/24 of the month succeeding such quarter as applicable.
- For first and second month the assessee can file the details of outward supplies through IFF (Invoice furnishing facility) between 1st and 13th of the succeeding month and will not be required to mention the same in GSTR 1 in last month of the quarter.
These invoices shall be reflected in GSTR 2A and GSTR 2B.
Maximum outward details to be shown in each month of IFF <= 50 lakhs
Payment Structure: Under this scheme, payment should be made on monthly basis by the 25th of the following month through Form PMT-06 (PRE-FILLED), either on the basis of fixed sum method or Self-assessment method
Method 1: Fixed Sum Method
Assessee filing on quarterly basis before opting the QRMP scheme: an amount equal to thirty five percent of the tax paid in cash in the preceding quarter.
Assessee filing on monthly basis before opting the QRMP scheme: an amount equal to the tax paid in cash in the last month of the immediately preceding quarter.
For ex: when return filing structure was on quarter basis.
Particulars Prev. Qtr. Current Qtr. (35% of Prev.)
CGST 100 35
SGST 100 35
IGST 200 70
Cess 50 17.5
When return filing structure was on monthly basis Particulars Prev. Qtr. Current Qtr. (100% of Prev.)
CGST 100 100
SGST 100 100
IGST 200 200
Cess 50 50
Method 2: Self-Assessment Method
Under this method, assessee can self-assess his liability payable in cash based on the ITC as updated on GSTR 2B for every month and accordingly deposit the difference through PMT-06.
Note: In both the above methods, no deposit is required if there is enough credit availability in the credit ledger or cash ledger or both.
Default migration to the Scheme of Existing Taxpayers
Default migration will only be of those taxpayer who have filed their return for last period as on or before due date. Default migration will be as such:
S.No. Class of Registered Person Default Option
1 Registered persons having aggregate turnover of up to 1.5 crore rupees who Quarterly Return have furnished FORM GSTR-1
on quarterly basis in the current financial year
2 Registered persons having aggregate turnover of up to Monthly Return 1.5 crore rupees who have furnished FORM GSTR-1 on
monthly basis in the current financial year
3 Registered persons having aggregate turnover more Quarterly Return than 1.5 crore rupees and up to 5 crore rupees in the preceding financial year
INTEREST Liability (payable through GSTR 3B):
Under method 1 (Fixed Sum) if pre calculated amount in PMT-06 is paid
- within due date then no interest is payable even if amount deposited is less than the liability payable for the month,
- paid after due date, then interest payable for the difference amount of liability payable as per section 50 of the CGST Act (i.e. 18%)
Under method 2 (Self-Assessment) Interest amount would be payable as per the provision of Section 50 of the CGST Act (i.e. 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.
Applicability of Late Fee: The late fee will be applicable on the delay in furnishing the quarterly GSTR-3B and GSTR 1 within due date, i.e., Rs. 50 per day (CGST: SGST) subject to a maximum late fees of Rs 5,000.
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.
OBSERVATION:
- This scheme has reduced the number of returns to be filed to 8 returns (4 GSTR 1 and 4 GSTR 3B) in a year as compared to 16 returns a year at present thereby reducing the compliance.
- However monthly compliance burden has not been reduced as proper compiling of data should be there so as to ensure the appropriate deposit of tax especially under self-assessment method and reduction of misreporting at the end of the qtr.
- Taxpayers have a better chance towards availment of ITC as quite a lot of taxpayers file returns on quarterly basis.
- From the government’s perspective, this is scheme is expected to plug revenue leakages and frauds as it could turn out to be a significant tool to curb the ongoing menace of fake invoicing vis-a-vis fake credits.
SOME COMMON FAQS
Whether QRMP scheme is available to all the Taxpayers?
This scheme is available to all taxpayers liable to file GSTR 3b and GSTR 1 (either on quarterly or on monthly basis) having turnover up to 5cr. Also no data should be already saved in GSTR 1 before opting for the scheme. Only after deleting the data one can opt the scheme.
Whether QRMP scheme is mandatory?
QRMP scheme is optional to comply with. Taxpayers can still comply in accordance with existing filing scheme.
What is Invoice Furnishing Facility (IFF)? (Based on news update as on 06.01.2021)
Invoice Furnishing Facility (IFF) is a facility provided to quarterly taxpayers to file their details of outward supplies in first two months of the quarter (M1 and M2). The facility will be similar to FORM GSTR-1 but will allow filing for only following tables:
a. 4A, 4B, 4C, 6B, 6C – B2B Invoices
b. 9B – Credit/ Debit Notes (Registered)
c. 9A – Amended B2B Invoices
d. 9C – Amended Credit/ Debit Notes (Registered)
Details to be uploaded in the IFF?
The following details are to be submitted by the small taxpayers if they opt for Invoice Furnishing Facility:
- B2B invoice details of sale transactions (both inter-state and intra-state).
- Debit and credit notes of the B2B invoices issued during the month.
Mandatory to file Invoice Furnishing Facility?
It is not mandatory to file IFF and invoices for all three months can be compiled directly in the GSTR 1. However filing of IFF on monthly basis provides with multiple benefits like:
- Buyers of goods from small taxpayers can claim ITC every month.
- It allows the monthly reconciliation of data and makes return filing easier.
- Small taxpayers can increase their business by providing faster ITC claims.
- Eases the compliance burden by reducing the volume of invoices to be uploaded at the end of the quarter.
I have submitted my GSTR-1/ IFF for a month; can I make changes in the form before filing IFF of that month?
The submit button will freeze the invoices uploaded in the GSTR-1/ IFF for that particular month. You will be not able to upload any further invoices for that month. In case you have missed adding any invoice, you can upload those invoices in the next month.
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