Introduction
Under the GST law, Quarterly Return Monthly Payment (QRMP) Scheme allows the registered person (i.e., who is required to furnish Form GSTR-1 & GSTR-3B and having aggregate turnover up to Rs. 5 crores) to furnish such return quarterly along with the monthly payment of tax by a simple challan in FORM GST PMT-06, with effect from January 01, 2021.
26th August 2021
From 1st September 2021, taxpayers will not be able to file GSTR-1 or use the IFF for August 2021 on the GST portal if they have pending GSTR-3B filings. It applies if GSTR-3B is pending for the past two months till July 2021 (monthly filer) or for the last quarter ending 30th June 2021 (quarterly filer), as per CGST Rule 59(6).
28th May 2021
At the 43rd GST Council meeting, the following was announced:
(1) The time limit to furnish B2B supplies on the IFF (optional facility for the taxpayers opting into the QRMP scheme), for May 2021 has been extended from 13th June to 28th June 2021.
(2) For any delayed submission of PMT-06 for April 2021 and May 2021, interest relief has been provided as follows:
(i) For April 2021, No interest is charged for delayed submission up to 9th June, whereas 9% of reduced interest is charged between 10th June and 9th July, and 18% of interest is charged thereafter.
(ii) For May 2021, No interest is charged for delayed submission up to 10th July, whereas 9% of reduced interest is charged between 11th and 25th July, and 18% of interest is charged thereafter.
(3) Quarterly GSTR-3B filing for Jan-Mar 2021 has also got interest and late fee relief as laid down here.
1st May 2021
The time limit to furnish B2B supplies on the IFF (optional facility for the taxpayers opting into the QRMP scheme), for April 2021 has been extended from 13th May to 28th May 2021.
What is QRMP Scheme?
Provision to Section 39(1) of the Central Goods and Services Tax (‘CGST’) Act, 2017 empowers the Government to notify a certain class of registered persons who shall furnish a return for every quarter or part thereof, subject to the manner prescribed in Rule 61A of CGST Rules, 2017.
Further, provision to Section 39(7) of the CGST Act, 2017 provides that the notified persons shall be required to pay the tax due to the Government within such time as may be prescribed considering particulars such as inward and outward supplies, input tax credit availed, etc. during a month.
In this regard, the CBIC notified a class of registered persons (discussed in Para 3) who are required to furnish a return every quarter from January 2021 onwards and pay the tax due every month.
Who is eligible for the QRMP scheme?
A registered person who is required to furnish a return in GSTR-3B, and who has an aggregate turnover of up to Rs.5 crore in the preceding financial year, is eligible for the QRMP Scheme. Further, 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 scheme from the next quarter.
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.
The quarterly GSTR-3B filing option was made available from 1st January 2021 onwards. It is clarified that this scheme is optional and can be availed based on GSTIN.
How to exercise Option for QRMP Scheme?
A registered person who intends to file his GSTR-3B quarterly should indicate the same on the GST portal, from the 1st of the second month of the preceding quarter until the last day of the first month of the quarter for which such option is being exercised.
For example: If A wishes to file quarterly returns for the quarter of Apr-Jun 2021, he should have opted for quarterly filing on the common GST portal between 1st February 2021 and 30th April 2021.
Once the registered person has opted for quarterly filing, he will have to continue to furnish his return every quarter for all future tax periods, except in the following situations:
- If the taxpayer becomes ineligible for furnishing a quarterly return (for example, if the aggregate turnover crosses Rs.5 crore during a quarter, then from the next quarter he will not be able to file quarterly returns). In such a case, the taxpayer must furnish GSTR-3B on a monthly basis.
- A registered person will not be eligible to opt for furnishing quarterly returns if the last return, which was due on the date of exercising such an option, has not been furnished.
For example, if the person is opting for quarterly GSTR-3B filing on 1st December 2020, he will need to furnish his GSTR-3B return for October 2020, which would have been the last return due on the date of exercising the quarterly filing option.
Deemed monthly/quarterly filing of GSTR-3B
The taxpayer has to follow the above procedure to opt for the quarterly GSTR-3B. However, in case of registered persons falling in the categories specified in the table below, who have furnished their GSTR-3B return for October 2020 by 30th November 2020, it shall be deemed that they have opted for monthly or quarterly filing as detailed below-
| S No. | Class of Registered Persons | Deemed Option |
| 1 | Registered individuals with an aggregate turnover of up to Rs.1.5 crore, who have furnished Form GSTR-1 quarterly in the current financial year | Quarterly GSTR-3B |
| 2 | Registered persons with an aggregate turnover of up to Rs.1.5 crore, who have furnished Form GSTR-1 monthly in the current financial year | Monthly GSTR-3B |
| 3 | Registered persons having an aggregate turnover exceeding Rs.1.5 crore and up to Rs.5 crore in the preceding financial year | Quarterly GSTR-3B |
The taxpayers referred to in the Sl. No. 2 in the above table could have changed the default option and opt for quarterly GSTR-3B filing between 5th December 2020 and 31st January 2021.
How to submit details of outward supplies?
The taxpayers who opted for the QRMP scheme can use the Invoice Furnishing Facility(IFF) which allows quarterly GSTR-1 filers to upload their invoices every month. One should keep the following points in mind before utilising the IFF:
- The IFF can be utilised only for the first two months of a quarter.
- The invoices relating to the last month of a quarter are to be uploaded in the GSTR-1 return only.
- There is no requirement to upload invoices in GSTR-1 if the same has been uploaded in the IFF.
- The taxpayer has to submit the B2B invoice details of sale transactions (both inter-state and intra-state) along with debit and credit notes of the B2B invoices issued during the month.
- The total net value of invoices that can be uploaded is restricted to Rs.50 lakh per month.
- The details submitted in IFF will be reflected in the GSTR-2A, GSTR-2B, GSTR-4A or GSTR-6A of the recipients as the case may be.
- The Invoice Furnishing Facility will come into effect from 1st January 2021.
Due dates for filing quarterly GSTR-3B
The due dates filing quarterly GSTR-3B has been notified as follows:
| S No | GST Registration in States and Union Territories | Due Date |
| 1 | Chhattisgarh, Madhya Pradesh, Gujarat, Dadra and Nagar Haveli, Daman and Diu, Maharashtra, Karnataka, Goa, Lakshadweep, Kerala, Tamil Nadu, Puducherry, Andaman and Nicobar Islands, Telangana and Andhra Pradesh | 22nd of the month succeeding such quarter |
| 2 | Jammu and Kashmir, Ladakh, Himachal Pradesh, Punjab, Chandigarh, Uttarakhand, Haryana, Delhi, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Mizoram, Manipur, Tripura, Meghalaya, Assam, West Bengal, Jharkhand and Odisha | 24th of the month succeeding such quarter |
Input Tax Credit Claims under QRMP Scheme
There is no procedural difference in the way Input Tax Credit (ITC) is claimed by a registered person opting into the QRMP scheme. The QRMP taxpayers who are using the self-assessment method of calculating the tax payments for the first two months of the quarter can consider the ITC available as per their GSTR-2B for the month. Accordingly, they can pay the balance as cash towards the GST liability.
However, the GSTR-2B for the quarter gets generated on 14th of the month following the quarter upon the filing of quarterly GSTR-1. Hence, the buyers who deal with the vendors under the QRMP scheme will need to refer to quarterly GSTR-2B for ITC claims.
Interest under QRMP scheme
The interest will be applicable as follows if the taxpayer opts for one of the following methods:
Fixed Sum Method (FSM) or popularly known as the 35% challan method:
| S No | Scenario | Interest to be paid |
| 1 | Tax liability mentioned in pre-filled form GST PMT-06 is paid by 25th of the following month | Nil |
| 2 | Tax liability mentioned in pre-filled form GST PMT-06 is not paid by 25th of the following month | 18% of the tax liability(from 26th of the following month till the date of payment) |
| 3 | The final tax liability for the first two months is less than or equal to the amount paid through pre-filled form GST PMT-06 | Nil |
| 4 | The final tax liability for the first two months is higher than the tax amount paid through pre-filled form GST PMT-06, and such excess liability has been paid within quarterly GSTR-3B due date | Nil |
| 5 | The final tax liability for the first two months is higher than the tax amount paid through pre-filled form GST PMT-06, and such excess liability has not been paid within quarterly GSTR-3B due date | 18% of the tax liability(from GSTR-3B due date* till the date of payment) |
The interest will be applicable as follows if the taxpayer opts for Self Assessment Method (SAM):
The taxpayer has to pay interest at 18% on the net tax liability which remains unpaid or paid beyond the due date for the first two months of the quarter.
It is important to note that the taxpayer has to pay interest at18% if there is any late payment of tax in the third month of a quarter. This is applicable irrespective of Fixed Sum Method (FSM), popular as 35% challan method, or Self Assessment Method (SAM).
Late fee under QRMP scheme
The late fee should be paid as follows if the quarterly GSTR-3B is not filed within due date, subject to a maximum late fees of Rs 5,000:
| Name of the Act | Late fee for everyday of delay | Late fee for everyday of delay(in case of ‘Nil’tax liability) |
| CGST Act | Rs.25 | Rs.10 |
| SGST Act | Rs.25 | Rs.10 |
| IGST Act | Rs.50 | Rs.20 |
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 PMT-06.
Persons Eligible to Opt for QRMP Scheme
The CBIC notified that the registered person having aggregate turnover of up to Rs. 5 crores in the preceding financial year and have opted to furnish a return for every quarter would be eligible for QRMP Scheme.
In case the aggregate turnover exceeds Rs. 5 crores during any quarter in the current financial year, the registered person shall not be eligible for the Scheme from the next quarter.
The option to avail the QRMP Scheme is GSTIN wise. Therefore, some GSTINs for a PAN might be eligible for the QRMP Scheme, and the remaining GSTINs might not be able to opt for the Scheme.
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. The amount shall be deposited by the 25th day of next month.
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.
A facility would be made available on the portal for generating a pre-filled challan in Form GST PMT-06. The person can use any of the following two options for the monthly payment of tax during the first two months:
| Method | Amount of Tax to be Paid in Form GST PMT-06 | Interest in Case Actual Liability Differs with the Tax Payment | Late Fee |
| Fixed Sum Method | a) If the last return is furnished quarterly, an amount equivalent to 35% of the tax liability paid for the previous quarter shall be paid
b) If the last return is furnished monthly, the tax liability paid in the return for the previous month shall be paid |
No interest would be required to be paid, provided tax is paid by the due date | No late fee would be applicable on delay in payment of tax using Form PMT-06 |
| Self-Assessment Method | The persons can pay the tax due by considering the tax liability on inward and outward supplies and the input tax credit available. | Interest would be applicable |
Conclusion
The Central Board of Indirect Taxes & Customs (CBIC) introduced Quarterly Return Filing and Monthly Payment of Taxes (QRMP) scheme under Goods and Services Tax (GST) to help small taxpayers whose turnover is less than Rs.5 crores. The QRMP scheme allows the taxpayers to file GSTR-3B on a quarterly basis and pay tax every month.
