Monthly & Quarterly GST Return Filing (GSTR-1, 3B, CMP-08)

GSTR-2B is a static, auto-populated ITC statement generated on the 14th of every month, showing ITC available based on suppliers' GSTR-1 filings cut off on the 13th. Unlike GSTR-2A (which is dynamic and updates as suppliers file late), GSTR-2B is fixed for each return period. From 2022 onwards, Rule 36(4) effectively limits ITC claims to what appears in GSTR-2B — you cannot claim ITC that your supplier has not reported in their GSTR-1 for the corresponding period. This means your ITC entitlement depends on your suppliers filing on time. GSTR-2B is not relevant to Composition Scheme taxpayers, who are not eligible for ITC in the first place.

GSTR-1 and GSTR-3B are separate filings. Filing GSTR-1 on time creates the ITC trail for your buyers but does not discharge your own tax liability. Tax liability is only discharged when GSTR-3B is filed and the payment is made. Interest at 18% per annum accrues on the unpaid tax from the due date of GSTR-3B — which is the 20th of the following month. Late fees accrue separately. The GST system calculates and shows interest automatically — it cannot be waived except through litigation or amnesty schemes.

Yes. ITC blocked because of a supplier's late GSTR-1 filing does not disappear — it becomes available in the GSTR-2B for the period in which the supplier actually files. You can claim the ITC in the GSTR-3B for that later period, subject to the annual time limit: ITC must be claimed by the earlier of the due date for the GSTR-3B of November following the end of the FY, or the due date for filing the annual return for the FY. ITC not claimed within this window is permanently lost.

QRMP — Quarterly Return Monthly Payment — allows businesses with aggregate turnover up to ₹5 crore to file GSTR-1 and GSTR-3B quarterly instead of monthly. Tax must still be paid monthly via PMT-06 challan — by the 25th of each of the first two months of the quarter. The Invoice Furnishing Facility (IFF) allows B2B invoice uploads in months 1 and 2 so buyers can access GSTR-2B credit without waiting for the quarterly GSTR-1. QRMP reduces the total number of annual returns filed but does not reduce the monthly tax payment obligation.

For regular taxpayers: ₹50 per day (₹25 CGST + ₹25 SGST) per return, subject to a maximum cap linked to turnover under the applicable notifications. For nil returns: ₹20 per day (₹10 CGST + ₹10 SGST). The GST Council has intermittently reduced late fees through amnesty schemes, but these are not recurring and cannot be relied upon. Late fees are in addition to 18% annual interest on any unpaid tax.

ASMT-10 is a notice for scrutiny of returns issued under Section 61 of the CGST Act. The department's system flags discrepancies between your GSTR-1 and GSTR-3B, between your GSTR-3B and GSTR-2B, or between your returns and third-party data from sources like TRACES or customs. The notice specifies the discrepancy and asks you to either accept the liability or explain the difference within 30 days. If you accept, you pay via DRC-03. If you explain, the department either accepts your explanation and closes the matter under ASMT-11, or escalates to a show-cause notice.

Yes. Amendments to GSTR-1 are made in the subsequent month's GSTR-1 through the amendment tables. B2B invoice amendments go in Table 9A (original document), 9B (revised document), or 9C (debit/credit notes). The amendment affects the buyer's GSTR-2B in the period the amendment is filed — not retrospectively in the original period. There is no separate amendment return; amendments are part of the next month's GSTR-1 itself.

Rule 37 requires that ITC claimed on an inward supply must be reversed if the corresponding payment to the supplier is not made within 180 days from the invoice date. The reversal is added back to the output tax liability in GSTR-3B for the period in which the 180-day limit expires. When the supplier is subsequently paid, the ITC can be re-claimed. This applies to all business purchases — not just large capital items. It has no relevance to Composition Scheme taxpayers, who claim no ITC.

Yes. Each GSTIN is a separate taxpayer in the GST system. GSTR-1 and GSTR-3B (or CMP-08, if on composition) must be filed independently for each GSTIN, for each return period. The ITC ledger, tax ledger, and return history are all GSTIN-specific. There is no consolidated multi-state filing mechanism. If you have 3 state registrations, you file 3 sets of returns every period — and 3 annual returns every year.

PMT-06 is the payment challan that QRMP scheme taxpayers use to pay monthly tax in the first two months of each quarter. It is not a return — no return is filed in those months. The challan is due by the 25th of each of the first two months of the quarter (e.g., for the Jul-Sep quarter: PMT-06 by 25 July and 25 August). The tax payment can be based on 35% of the previous quarter's tax paid, or the actual tax liability for the current month calculated by the taxpayer, or the balance in the Electronic Cash Ledger. The final quarter-end GSTR-3B true-ups or refunds the monthly PMT-06 payments.

For proprietorships and partnership firms, returns can be filed using Aadhaar-based EVC (OTP). For companies and LLPs, returns must be filed using a Class 3 DSC of the authorised signatory. There is no OTP-based filing option for companies and LLPs. If the authorised signatory's DSC expires or the signatory changes, the DSC must be updated and re-registered on the GST portal before any further returns can be filed. A lapse in DSC currency can delay return filing and trigger late fees.

For businesses above the e-invoice threshold (currently ₹5 crore aggregate turnover), B2B invoices must be registered on the Invoice Registration Portal (IRP) to generate an IRN (Invoice Reference Number) and QR code. The IRP then auto-pushes the invoice data to GSTR-1 — so the GSTR-1 entries are auto-populated from e-invoices rather than manually uploaded. However, B2C invoices, credit notes, debit notes, and certain other documents are not covered by e-invoicing and must still be reported separately in GSTR-1. Not all invoice types are auto-populated; manual data entry remains necessary for non-e-invoice documents. E-invoicing does not apply to Composition Scheme taxpayers, who cannot issue tax invoices in the first place.

E-invoicing is currently mandatory for registered taxpayers with aggregate turnover exceeding ₹5 crore in any preceding financial year. The threshold has been progressively reduced over successive notifications since 2020 (starting from very large taxpayers and stepping down over time to the current ₹5 crore level). If your turnover crosses ₹5 crore in any FY, you become a mandatory e-invoicer from the subsequent FY. Certain sectors are exempt from e-invoicing regardless of turnover: banking, insurance, NBFCs, GTA (Goods Transport Agencies), passenger transport, and multiplex cinemas.

If your supplier's GST registration is cancelled retrospectively — which the department can do in fraud cases — any ITC claimed on invoices from that supplier during the cancelled period becomes potentially reversible, even if you claimed it in good faith. Section 16(2)(c) requires that the tax charged by the supplier must actually have been paid to the government. If the supplier never remitted the tax, your ITC claim is technically invalid even though you paid the supplier and the invoice appeared in GSTR-2B. This is an area of active litigation before multiple High Courts.

CMP-08 is the quarterly statement-cum-challan filed by taxpayers registered under the Composition Scheme (Section 10 of the CGST Act). It replaces GSTR-1 and GSTR-3B entirely for composition dealers. In CMP-08, the taxpayer self-declares turnover for the quarter and pays tax at the flat composition rate — 1% for traders and manufacturers, 5% for restaurants and food-service businesses, and 6% under the separate notified scheme for other service providers — with no ITC offset available. CMP-08 is due by the 18th of the month following the end of each quarter.

No. Composition dealers are legally barred from issuing a tax invoice and from collecting GST separately from customers. Instead, they must issue a 'Bill of Supply' which does not show any GST component. The words 'composition taxable person, not eligible to collect tax on supplies' must be displayed at every place of business and on every Bill of Supply. Charging GST separately as a composition dealer is a compliance violation with penal consequences, since it implies collection of tax not authorised to be collected.

CMP-08 attracts a late fee of ₹200 per day of delay (₹100 CGST + ₹100 SGST), subject to a cap of ₹5,000 per return. In addition, interest at 18% per annum applies to any tax portion paid late, calculated from the due date (18th of the month after quarter end) to the date of actual payment. Because CMP-08 tax is quarterly and composition dealers have no ITC to offset, the full self-assessed amount is a cash outflow — meaning a missed CMP-08 payment can create a larger absolute interest exposure relative to turnover than a similarly-sized regular filer's monthly shortfall.

The moment aggregate turnover (across all GSTINs held under the same PAN) crosses ₹1.5 crore (₹75 lakh for specified special-category states), composition eligibility ends immediately — not at the end of the financial year. The taxpayer must file Form CMP-04 to formally opt out of the Composition Scheme, and from that date forward must comply with regular scheme obligations: charging GST on tax invoices, filing GSTR-1 and GSTR-3B (or QRMP as applicable), and claiming ITC prospectively. A transition declaration (Form ITC-01) can be filed to claim ITC on the stock of inputs, semi-finished, and finished goods held as of the date of conversion, and on capital goods (reduced proportionately for the period already used).

No. Composition Scheme registrants under Section 10 of the CGST Act are barred from making inter-state outward supplies of goods. If a composition dealer needs to sell to a customer in another state, they cannot do so under the composition GSTIN — they must either exit the scheme voluntarily or restructure the transaction (for example, through a separate regular-scheme entity). Composition dealers also cannot supply through an e-commerce operator required to collect tax at source, and cannot supply certain notified goods and services regardless of turnover.

No, they serve different purposes and both are mandatory. CMP-08 is filed quarterly and is primarily a payment mechanism — a self-assessed statement of turnover and tax paid for that quarter. GSTR-4 is filed annually (by 30 June following the financial year) and is the consolidated annual return summarising all four quarters, inward supplies, and other prescribed details. A composition dealer who files all four CMP-08 statements on time but skips GSTR-4 is still non-compliant and subject to GSTR-4-specific late fees and interest.

Yes, if your aggregate turnover is within the composition threshold, you can opt into the Composition Scheme by filing Form CMP-02 before the start of the financial year in which you want the scheme to apply — the option takes effect from the beginning of that financial year, not mid-year. Along with the switch, you may be required to reverse ITC on stock held as of the date of transition, since composition dealers cannot hold unutilised ITC. The reverse transition (composition to regular) can happen either voluntarily or, as described elsewhere, mandatorily on breaching the turnover threshold.

GST is an Indian tax law with no direct UAE equivalent filing mechanism — UAE VAT is a separate regime administered by the UAE Federal Tax Authority. For clients with operations in both jurisdictions, PNPC's India team manages GSTR-1/GSTR-3B or CMP-08 for the Indian entity, while coordinating with our UAE presence for VAT return filing on the UAE side. The two are independent compliance obligations; there is no GST credit or offset available for UAE VAT paid, or vice versa.

This is a common discovery in GST clean-up assignments when a business changes its compliance provider. The first step is to pull the full filing history from the GST portal (available under 'Returns Dashboard') to quantify the actual pattern of delay, interest accrued, and late fees paid or outstanding. If tax itself was paid late (not just the return filed late), interest liability may still be outstanding even if the department has not yet issued a demand. PNPC's onboarding process for any new client includes this historical review before taking over ongoing compliance.

Yes. A nil GSTR-3B (or nil CMP-08 for composition dealers, or nil GSTR-1) must still be filed even with zero activity. GST registration does not auto-suspend for inactivity, and non-filing of even a nil return attracts late fees. A simplified nil-filing process via SMS is available for GSTR-3B in certain circumstances, but the underlying obligation to file remains regardless of activity level.

PNPC structures GST return filing engagements as a fixed-fee annual or monthly retainer scoped to your filing frequency (monthly, QRMP, or CMP-08), transaction volume, and number of GSTINs. This is a deliberate choice — a per-return fee model can create an incentive to file quickly rather than reconcile thoroughly, whereas a retainer aligns our incentive with getting the reconciliation right the first time. Exact pricing depends on invoice volume, number of GSTINs, and reconciliation complexity, and is scoped during an initial consultation rather than quoted generically before reviewing your data.

GSTR-9 is the annual return that consolidates a regular taxpayer's full-year GSTR-1 and GSTR-3B data — it is a summary, not a new set of transactions. GSTR-9C is a reconciliation statement between the GSTR-9 figures and the taxpayer's audited financial statements, required above a specified turnover threshold, and must be certified. PNPC prepares GSTR-9 as part of the annual reconciliation cycle for all regular-filing clients and coordinates GSTR-9C preparation with the statutory audit team where the turnover threshold applies. Composition dealers file GSTR-4 instead of GSTR-9/9C.

Yes, and this is one of our more common onboarding scenarios. PNPC first pulls the complete filing history from the GST portal to establish exactly which returns are outstanding, computes accrued interest and late fees on any unpaid tax, and prioritises clearing the backlog before resuming the regular monthly or quarterly cycle. Where GSTR-3B is pending for a period, GSTR-1 for a later period cannot be filed until the backlog clears — so backlog resolution has to happen in the correct sequence.

Rule 86B restricts the use of ITC in the electronic credit ledger to discharge output tax liability — for taxpayers with monthly taxable turnover above a specified threshold (excluding exempt and zero-rated supply), at least a small percentage of the output tax liability must be paid in cash, not entirely through ITC, subject to certain exceptions (such as taxpayers who have paid a meaningful amount of income tax in preceding years, or received a substantial refund of unutilised ITC). This rule targets fraudulent ITC availment schemes where entities generate large turnover with no real cash tax payment.

Under Section 36 of the CGST Act, every registered person must retain books of account and records for a minimum of 72 months (6 years) from the due date of filing the annual return for the relevant year. This includes invoices, purchase and sales registers, ITC records, e-way bills, and any records substantiating the return data filed. If proceedings such as an appeal or investigation are pending at the end of that period, records must be retained until final disposal of the proceeding, plus one year.

The ₹1.5 crore (or ₹75 lakh special-category) composition threshold is computed on aggregate turnover across all GSTINs registered under the same PAN, not on a single registration in isolation. If a person holds a composition GSTIN in one state and a regular GSTIN in another state, and the combined aggregate turnover exceeds the composition ceiling, the composition GSTIN loses eligibility even if that specific registration's standalone turnover is well within the limit.

Ineligible ITC wrongly availed and utilised must be reversed along with interest under Section 50, and in cases involving fraud or wilful misstatement, a penalty can also apply. Common categories of blocked credit under Section 17(5) include motor vehicles (with specified exceptions), food and beverages, club memberships, and works contract services for immovable property (with exceptions), among others. If the error is identified before a departmental notice, voluntary reversal via DRC-03 with applicable interest is the standard corrective route and is viewed far more favourably than a department-detected discrepancy.

Yes. Beyond automated ASMT-10 scrutiny, the department can also conduct a departmental audit under Section 65 or a special audit under Section 66 of the CGST Act. PNPC represents clients through the full audit process — compiling the requested documentation, attending department meetings, responding to audit observations, and negotiating or contesting any resulting demand. This is distinct from the routine monthly/quarterly filing engagement and is scoped separately when it arises.

Originally the Composition Scheme under Section 10 was primarily for suppliers of goods and restaurant services. A separate notified scheme extended composition-style flat-rate taxation to other service providers (and mixed suppliers of goods and services) with turnover up to ₹50 lakh, at a 6% flat rate. This service-provider composition scheme has its own turnover ceiling — distinct from and lower than the ₹1.5 crore ceiling that applies to goods traders and manufacturers.