Quarterly Return Monthly Payment and Registration: Features and Payment Mechanism

Quarterly Return & Monthly Payment and Registration Amendments by CMA Prasanna Kumar K C 1 18thFeb 2021 GST

Quarterly Return Monthly Payment (QRMP) Features:- Register Person Who s Turnover upto 5 Crores in current & preceding FY [PAN Level] and Presently filing monthly GSTR3B [Sec. 37(1) and Monthly / Quarterly GSTR1 Sec. 39(1)] Shall file GSTR3B & GSTR1 Quarterly Pay Taxes Monthly through PMT-06 Option is not available for the RP who has not furnished their last due GSTR -3B. 2 18thFeb 2021 GST

Quarterly Return Monthly Payment (QRMP) Furnishing Invoice-Wise Details GSTR1 to be filed Quarterly Invoice Furnishing Facility [IFF] : IFF tool can be used to upload B2B Invoices on monthly basis During 1st& 2ndMonth of a Quarter Total Value of the invoices uploaded through the Tool shall not exceed INR 50 Lakhs Option can be availed GSTN wise 3 18thFeb 2021 GST

Quarterly Return Monthly Payment (QRMP) Payment Mechanism Payment shall be on monthly basis through PMT-06 Challan 1st& 2ndMonth of the Qtr. At the end of the Quarter Payment shall be made through GSTR3B 1st& 2ndMonth of the quarter Payment can be made under Fixed Sum Method [FSM] and Self Assessment Method [SAM]. RP allowed to opt for any of the 2 payments method in the first 2 months of the quarter. Such tax deposited can t be utilized for any other purpose. 4 18thFeb 2021 GST

Quarterly Return Monthly Payment (QRMP) Payment Mechanism .. Cont.. 1.Fixed Sum Method (FSM): [System Calculated] Tax paid in cash during Jan 21 - Mar 21 quarter S No Tax Payable @ Apr 21 and May 21 Type of Taxpayer Tax to be paid Filed Quarterly GSTR-3B last Qtr. 35% of tax paid in cash in the preceding quarter 100% of tax paid in cash in the last month - preceding quarter 1 GST 10,000 GST 3,500 Filed monthly GSTR- 3B Last Qtr. 2 GST 5,000 GST 5,000 Self Assessment Method (SAM): RP can calculate Net Tax Liability [Gross Liability less ITC] and pay through PMT-06 Challan 5 18thFeb 2021 GST

Quarterly Return Monthly Payment (QRMP) Exercising QRMP Option A RP can opt for QRMP scheme by updating at GST portal [Login-> Services -> Returns -> Opt-in for quarterly return] within the prescribed dates: - Q1 1stFeb to 30thApr For Jan Mar21 option should have exercised Jan2021 1stMay to 31stJuly Q2 before 31st 1stAug to 31stOct Q3 1stNov to 31stJan Q4 Once the RP has opted for QRMP, he will have to continue to furnish his return every quarter for all future tax periods, except in the following situations:- if the aggregate turnover exceeds Rs.5 crore during a quarter, then from the next quarter he will not be able to file quarterly returns 6 18thFeb 2021 GST

Quarterly Return Monthly Payment (QRMP) Deemed monthly/quarterly filing of GSTR-3B RP who wish to opt for the quarterly/ monthly at GSTN portal, else it shall be deemed that they have opted for monthly or quarterly filing as detailed below: - S No. Class of Registered Persons Deemed Option RP with an aggregate TO up to Rs.1.5 crore, Filed Quarterly - GSTR-1 in the current FY Quarterly GSTR- 3B 1 RP with an aggregate TO up to Rs.1.5 crore, Filed Monthly GSTR-1 in the current financial year Monthly GSTR- 3B 2 RP with an aggregate TO > Rs.1.5 crore and up to Rs.5 crore in the preceding financial year Quarterly GSTR- 3B 3 7 18thFeb 2021 GST

Quarterly Return Monthly Payment (QRMP) Statutory Dates Monthly For 1st& 2ndMonth of the Quarter:- Upload B2B Invoices through IFF by 13thof succeeding Month OPTIONAL PMT-06 25thSucceeding Month Quarter for 3rdMonth of the Quarter: - GSTR1 13thof succeeding month GSTR3B 22 / 24 of succeeding month 8 18thFeb 2021 GST

Quarterly Return Monthly Payment (QRMP) Interest and Late Fee S.No 1 Under Fixed Sum Method Scenario Interest A B Paid as per Pre-filled form of PMT-06 by 25th of the following month Not Paid as per pre-filled form of PMT-06 by 25th of the following month Liability for the first 2 months is less than Tax paid through pre-filled form GST PMT-06 Liability for the first 2 months is higher than the tax paid through pre-filled form GST PMT-06, & paid within quarterly GSTR-3B due date Liability for the first 2 months is higher than the tax paid through pre-filled form GST PMT-06, & such excess liability not paid within quarterly GSTR-3B due date Nil 18% (26th till DoP*) Nil C D Nil 18% (GSTR-3B due date till DoP*) E 2 Under Self Assessment Method 18% (26th till DoP*) Interest Payable as per Sec. 50 9 18thFeb 2021 GST

Quarterly Return Monthly Payment (QRMP) Interest and Late Fee Cont.. Late Fee Delay in furnishing outward supplies late fees as per Sec. 47 Delay in Tax payment for first 2 months of the quarter No Late Fees 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:- Late fee for every day of delay (in case of Nil tax liability) Rs. 10 Rs. 10 Rs. 20 Late fee for every day of delay Name of the Act CGST Act SGST Act IGST Act Rs. 25 Rs. 25 Rs. 50 10 18thFeb 2021 GST

Quarterly Return Monthly Payment (QRMP) Invoice Furnishing Facility (IFF) [Rule 59(2)] The IFF can be used only when a taxpayer whose turnover is up to Rs.5 crores & Optional. The IFF will come into effect from 01.01.2021. The IFF can be utilized 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 shall to submit the B2B invoices, debit and credit notes. The total 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 11 18thFeb 2021 GST

Amendments w.r.t Registration Provisions Amendments @ GST REG-01 Aadhar Authentication Option Other than AA option : Biometric Based Aadhar Authentication + Photos : Taking biometric information, photograph and verification of such other KYC documents, as notified Verification of the original document with documents uploaded in FORM GST REG-01 @ Facilitation Center as notified by the Commissioner Time limit for approval of registration application from 3 days to 7 days Assistant Commissioner may physically visit the place of business and registration shall be granted within 30 days of submission of application, after physical verification of the place of business in the presence, in the following cases: A person fails to undergo authentication of Aadhaar number or does not opt for authentication of Aadhaar Number The proper officer, with the approval of an officer authorized by the commissioner not below the rank of Asst. Commissioner, deems it fit to carry out physical verification of places of business. 12 18thFeb 2021 GST

Amendments w.r.t Registration Provisions Suspension ofRegistration Increaseindiscretionarypowers tosuspend[Rule21A] To suspendGST registrationon accountof reconciliationdifferencesbetween Outward SuppliesinGSTR1ismorethanGSTR3B ITC availedinGSTR3Bvs ITC reported by suppliers (110% of GST2B) Such otheranalysisasrecommendedby GST Council Intimationbeingsendover commonportal or email Opportunity of affording personal hearingdeletedfrom therule Impactof suspension RPwillnot be ablemaketaxablesuppliesby issuingtaxinvoice[R.21A(3)] Refunds willnot be granted[R.21A(3A)] In caseof reconciliationdifferences:- Registrationshallbe suspended& noticefor cancellationtobe issued Timelimittorespond isprovided 30 days However, order for cancellationcanbeissued within30 days 13 18thFeb 2021 GST

Amendments w.r.t Registration Provisions Cancellation of registration Additional Circumstance in Rule 21 Existing Provisions Additional Provisions Proper officer has a reason to believe that registration is liable to be cancelled [u/s 29 of u/r 21] : e. Avails ITC in violation of Sec. 16 or rules made thereunder [Compliance of 180 days rule, September time limit, payment not done by vendors] a. Does not conduct business from declared PoB f. Furnishes outwards supplies in GSTR-1 in excess of GSTR-3B for one or more tax periods b. Issues tax invoice / bill of supply w/o supply of goods or services c. Violates provisions u/s 171 or rules thereunder g. Violates 86B provisions d. Violates provision of Rule 10 A 14 18thFeb 2021 GST

QRMP and Amendments w.r.t Registration Provisions Thank You 15 18thFeb 2021 GST Behind Every Successful Business Decision, There Is Always A CMA