Quarterly Return Monthly Payment (QRMP) scheme Analysis

This is an attempt to apprise you in detail of the Quarterly Return-Monthly Payment (QRMP) scheme has recently been launched by the Central Board of Indirect Taxes and Customs (CBIC).

Please note that a Quarterly Return-Monthly Payment (QRMP) scheme has recently been launched by the board and a circular bearing no. 143/13/2020-GST dated 10 November 2020 has been issued in this regard, wherein taxpayers having turnover b/w 1.5 crores-5 crores may choose to file both the returns on quarterly basis. For all taxpayers whose turnover falls within the said turnover range, QRMP has been activated by the GSTN as default for the Qtr Jan-Mar 2021 and thus are is required to file quarterly return GSTR1 and GSTR3B for this period and need to make monthly payment as per below mechanism:

IFF: This scheme comes with an option to continuously upload details for supplies made to registered persons in an Invoice Furnishing Facility (IFF) so as to enable seamless flow of credit through form GSTR2A and GSTR2B and is available for 1^st and 2^nd month of the quarter. IFF is available between the 1st day of the succeeding month till the 13th day of the succeeding month and the said details of outward supplies shall, however, not exceed the value of fifty lakh rupees in each month. Any remaining details of outward supplies shall be uploaded at the time of quarterly return filing.

Payment of tax: Payment of tax shall be required to be made on monthly basis 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:

1. 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

2. 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

Interest implications when liability discharged under:

1. 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 by the due date 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

2. 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 

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.

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.

Opt-in: 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. 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.

Opt-out: It is also clarified that such registered person, whose aggregate turnover crosses 5 crore rupees 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 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.

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 and you may choose to opt out of the same to follow regular mechanism for the ongoing return periods.

Trust the above suffices. In case of any further query, please feel free to revert.