With an intent to ease of performing company & as a trade facilitation measure, GST Council in its 42nd Meet held on 5th October 2020 proposed new GST Return Filing System for the smaller taxpayers getting aggregate annual turnover (hereinafter AATO) up to Rs 5 crore in the preceding FY i.e. 2019-20, with impact from January 01, 2021. The pretty try behind the Introduction of this scheme is to decrease the month-to-month return filing burden on the smaller taxpayers. The council suggested that the taxpayers getting the AATO up to Rs 5 Crore is permitted to furnish GSTR-3B quarterly with a month-to-month payment of GST Liability, from January 01, 2021, onwards. The government has issued numerous notifications to implement this scheme & circular to clarify this scheme in easy terms & to make certain uniformity in its implementation
In the ensuing paragraphs, we have discussed the QRMP scheme in-depth to provide far better clarity in regards to this scheme & also attempted to provide the answers to all of the concerns roaming in the thoughts of the taxpayers & practitioners, about this scheme. To begin with the query that who can opt for the QRMP scheme: As per current Circular, the Following registered individual can file quarterly returns and spend tax month-to-month w.e.f. 01.01.2021:
- A Registered individual who has an AATO of up to Rs 5 Cr. in the prior economic year is eligible.
- Any individual getting a new registration or opting out of the Composition Scheme can also opt for this Scheme.
- The choice to avail this Scheme can be availed GSTIN sensible. Therefore, couple of GSTINs for that PAN can opt for the Scheme, and the remaining GSTINs can stay out of the Scheme.
When can a individual opt for the QRMP scheme: As per current Circular: –
- The Facility to avail the Scheme on the widespread portal would be obtainable all through the year.
- A registered individual can opt-in for any quarter from the initially day of the second month of the preceding quarter to the final day of the initially month of the quarter. For Example, a registered individual intending to avail of the Scheme for the quarter ‘July to September can exercise his option from May 01 to July 31.
- Option for QRMP Scheme, once exercised, will continue till the taxpayers revise the option or his AATO exceeds Rs 5 Cr.
Invoice furnishing facility (hereinafter ‘IFF’) for taxpayers opting for QRMP Scheme: The taxpayers who opted for the QRMP scheme can avail the choice of the IFF and furnish their particulars of outward provide on month-to-month basis for the initially two months so that the recipient of such outward supplies get these invoices reflected in their respective GSTR-2A & GSTR-2B. The particulars of an outward provide in IFF need to have to be furnished by the 13th of the succeeding month. The stated particulars of outward supplies shall, nevertheless, not exceed the worth of fifty lakh rupees in each and every month. Thus, the particulars of outward supplies by the taxpayer throughout a quarter shall consist of particulars of invoices furnished utilizing IFF for each and every of the initially two months and the particulars of invoices furnished in Kind GSTR-1 for the quarter.
Manner of month-to-month payment of taxes, if a individual opts QRMP scheme: The registered individual below the QRMP Scheme would be essential to spend the tax due in each and every of the initially two months of the quarter by depositing the due quantity in Kind GST PMT-06, by the 25th of the month succeeding such month. The current circular lay down two alternatives for the month-to-month payment of tax throughout the initially two months.
FIXED SUM Strategy: Under this strategy, the facility is becoming created obtainable on the portal for creating a pre-filled challan in Kind GST PMT-06 for an quantity equal to thirty-5 % (35%) of the tax paid in money in the preceding quarter exactly where the return was furnished quarterly or equal to the tax paid in money in the final month of the instantly preceding quarter exactly where the return was furnished month-to-month.
SELF ASSESSMENT Strategy: The stated persons, in any case, can spend the tax due by taking into consideration the tax liability on inward and outward supplies and the input tax credit obtainable, in Kind GST PMT-06. To facilitate ascertainment of the ITC obtainable for the month, an auto-drafted input tax credit statement has been created obtainable in Kind GSTR-2B, for just about every month.
Any quantity of tax paid in excess can be claimed as a refund by the taxpayers. However, refund shall be permitted only right after the return in Kind GSTR-3B for the stated quarter has been furnished. Further, this deposit can not be utilised by the taxpayer for any other goal till the filing of return for the quarter.
Applicability of interest: In case FIXED SUM Strategy is been opted by the taxpayer then no interest would be payable for the quantity quick paid in the initially two months’ conditional to complete tax liability is discharged for the quarter in the Kind GSTR-3B.
On the contrary, if the taxpayer opted SELF ASSESSMENT Strategy, the Interest quantity would be payable as per the provision of Section 50 of the CGST Act for tax or any element thereof (net of ITC) which remains unpaid/paid beyond the due date for the initially two months of the quarter.
Applicability of Late costs: Late charge is applicable for delay in furnishing of return/particulars of outward provide as per the provision of Section 47 of the CGST Act. As per the Scheme, the requirement to furnish the return below the proviso to sub-section (1) of Section 39 of the CGST Act is quarterly. Accordingly, a late charge would be applicable for delay in furnishing of the stated quarterly return/particulars of outward provide.
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QRMP is a step towards decreasing the compliance of the MSME sector, nonetheless, there is an apprehension about the general interlocking of the compliance framework from January 01, 2020. Since the GST Liability is to be paid on a month-to-month basis, the month-to-month reconciliation of the exact same is essential to be ready by the taxpayers to hold the payment of taxes on track.