Categories: GST E-Invoice

Invoice Furnishing Facility (IFF) Under QRMP Scheme

Overview of Invoice Furnishing Facility (IFF) Under QRMP Scheme

  • The Invoice Furnishing Facility (IFF) means that small taxpayer uploads their invoices on a monthly basis.
  • On 10.11.2020, the Central Board of Indirect Taxes & Customs (CBIC) notified the Invoice Furnishings Facility via notification number 82/2020-Central Tax.
  • The CBIC introduced the QRMP scheme GST to help small taxpayers whose turnover is less than Rs.5 crores.

  • An Invoice Furnishing Facility has been provided to GST Taxpayers under QRMP Scheme system (Quarterly filers of Form GSTR-1 and also of Form GSTR-3B returns), as per Rule-59(2) of the CGST Rules, 2017.
  • GST Taxpayers who have opted for quarterly filing frequency under the scheme can file their details of outward supplies (B2B invoices only) for the first two months of a quarter (M1 and M2 respectively of a Quarter) in IFF.

  • GST Taxpayers under the QRMP Scheme (Quarterly Fillers of Form GSTR-1 and Form GSTR-3B returns)  were provided with the Invoice Furniture Facility (IFF) as per sub-rule (2) of Rule-59 of the CGST Rules, 2017.
  • Taxpayers who have chosen for a quarterly filing intensity under the scheme may submit their outward supply details (B2B invoices only) to the IFF for the first two months of the quarter (M1 and M2 quarters respectively).
  • For instance, B2B invoices for the months of April (M1) and May (M2) may only be submitted in IFF by a taxpayer for the months of April (Apr-June qtr.).
  • Example for Apr-June qtr., B2B invoices only for the months of April (M1) and May (M2) can be filed in the Invoice Furnishing Facility by a taxpayer.

How to will provide documents in the Invoice Furnishings Facility (IFF) under the QRMP Scheme

The salient features of the Invoice Furnishing Facility are provided as under.

  • Invoice Furnishing Facility is a facility like Form GSTR-1, and it allows the filing of details of B2B invoices in the following tables only:  a. Return under 4A, 4B, 4C, 6B, 6C – B2B Invoices

9B – Credit / Debit Notes (Registered) – CDNR
9A – Amended B2B Invoice – B2BA
9C – Amended Credit/ Debit Notes (Registered) – CDNRA

  • The option to upload details in of Invoice Furnishing Facility can be availed till the 13th of the subsequent month.
  • Any invoices remaining to be furnished can be filed using the Invoice Furnishing Facility in the subsequent month Invoice Furnishing Facility or in the quarterly Form GSTR-1. For e.g. for Apr-June qtr., B2B invoices for the month of April (M1) can be filed in IFF by a taxpayer till 13th May.
  • Invoice Furnishing Facility which is not filed till the due date of 13th of the subsequent month will expire.
  • To submit the Invoice Furnishing Facility form for M1 & M2 of the month, log in to GST Portal and navigate to Returns > Services > Returns Dashboard > File Returns and then Select the FY and Return Filing Period (M1/M2 of a quarter) and click on the SEARCH button to file the of Invoice Furnishing Facility forms for M1 or M2 month.

  • IFF is an optional facility provided to taxpayers under the QRMP scheme to pass on Input Tax Credit (ITC) to their recipients for M1 and M2 months of a quarter.
  • However, filing of Form GSTR-1 for M3 month of a quarter is mandatory.
    • GST-related Records submitted/ uploaded in the Invoice Furnishing Facility by the Supplier will reflect in the Form GSTR-2A/2B of the Recipient.
    • GST Supplier Taxpayers can also submit/upload details in their Invoice Furnishing Facility(IFF), through JSON file, generated using Returns Offline Tool.
    • Records filed in Invoice Furnishing Facility(IFF) required not to be filed again in Form GSTR-1 of that quarter.
    • Only the details saved in IFF can be deleted/edited using the RESET button. Once GST Return filed or submitted, then these filed details can’t be deleted after the submitting action.

Monthly GST Tax payments under the QRMP scheme:

The taxpayer should first pay the tax in the form of GST PMT-06 by the 25th of the following month, for the first and second months of the quarter.

Taxpayers may pay their monthly tax liability in either the Fixed Sum Method (FSM) or the Self-Assessment Method (SAM).

Fixed Sum Method (FSM):

The taxpayer should pay the amount of tax indicated in the pre-filled call in the form of GST PMT-06 for an equivalent amount to 35% of the tax paid in cash.

S No Type of Taxpayer Tax to be paid
1 Who needed to file GSTR-3B quarterly for the last quarter 35% of tax paid in cash in the preceding quarter
2 Who needed to file GSTR-3B monthly during the last quarter 100% of tax paid in cash in the preceding month of the immediately preceding quarter

What is the Interest applicable under the QRMP scheme

The interest will be applicable as follows if the taxpayer opts for Fixed Sum Method (FSM):

S No Situation Rate of Interest to be paid
1 GST Tax liability mentioned in pre-filled form GST PMT-06 is paid by 25th of the upcoming next month Nil
2 GST Tax liability mentioned in pre-filled form GST PMT-06 is not paid by 25th of the upcoming next month Eighteen percent of the tax liability

(from 26th of the following month till the date of payment)

3 GST Tax liability for first 2 months is less than or equal to amount paid via pre-filled form GST PMT-06 Nil
4 Final GST Tax liability for first 2 months is higher than  tax amount paid via pre-filled form GST PMT-06, and such excess liability has been paid within quarterly GSTR-3B due date Nil
5 The final GST Tax liability for the first 2 months is higher than the tax amount paid Via pre-filled form GST PMT-06, and such excess liability has not been paid within the quarterly GSTR-3B due date Eighteen percent of the tax liability

(from GSTR-3B due date* till the date of payment)

*22nd or 24th of the month succeeding such quarter based on the state of the taxpayer.

The interest will be applicable as follows if the taxpayer opts for the Self-Assessment Method. The taxpayer has to pay interest @ 18% on the net tax liability which remains unpaid or paid beyond the due date for the first two months of the quarter.

Also Read : 

What is a late fee payable under the QRMP scheme

The applicable late fee shall be paid as below if the quarterly GSTR-3B is not submitted within the deadline date, subject to a maximum late fees of INR 5k:

Kind of the Act Applicable late fee for every

day of delay

Applicable late fee for every

day of delay

(if the ‘Nil’

tax liability)

CGST Act Rs.25 Rs.10
SGST Act Rs.25 Rs.10
IGST Act Rs.50 Rs.20
  • Nevertheless, it is explained that there is no late fee for late payment of tax in the first 2 months of the quarter in the form of GST PMT-06.
  • E-Invoicing is India’s largest tax reform next to GST, which will soon cover every business. Stay in front of the curve! Check out our post to get an outline of the e-invoice system.

Notes : Clarification in respect of applicability of Dynamic Quick Response (QR) Code on B2C invoices and compliance of notification 14/2020- Central Tax dated 21st March, 2020-  Clarification on applicability on QR Code Notification 14/2020

What are the deadline dates for submitting quarterly filing of GSTR-3B

The deadline dates for submitting quarterly GSTR-3B has been notified as below :

S No GST Registration in States and Union Territories Due Date
1 Karnataka, Goa, Lakshadweep, Daman and Diu, Maharashtra,Telangana, Kerala, Tamil Nadu, Puducherry, Andaman and Nicobar Islands, Chhattisgarh, Madhya Pradesh, Gujarat, Dadra and Nagar Haveli, and Andhra Pradesh 22nd of the month upcoming Next such quarter
2 West Bengal, Jharkhand and Odisha, Uttarakhand, Haryana, Delhi, Rajasthan, Jammu and Kashmir, Ladakh, Himachal Pradesh, Punjab, Chandigarh,Uttar Pradesh, Bihar, Mizoram, Manipur, Tripura, Meghalaya, Sikkim, Arunachal Pradesh, Nagaland, Assam, 24th of the month  upcoming Next  such quarter

Benefits of using such an Invoice Furniture Facility

The potential benefits of the Invoice Furniture Facility are as follows:

  • Relieves the burden of compliance by reducing the volume of invoices to be submitted at the end of the quarter.
  • It allows for a monthly data reconciliation and makes it easier to file returns.
  • Purchasers of goods from small taxpayers can claim ITC on a monthly basis.
  • Small taxpayers can boost their business by making ITC claims faster.

This is an excellent strategy to help both small taxpayers and small taxpayers’ buyers. This facility will indirectly support small taxpayers to improve their businesses by providing faster ITC makes a claim to their buyers. Even so, this will raise the cost of compliance for them.

It is, therefore, necessary to make a comparison between the benefits of opting for IFF and the costs involved. It is decent to opt-in for this facility if a small taxpayer raises large amounts of B2B invoices in one quarter compared to B2C invoices.

 

All taxpayers with Annual Total Sale up to INR 5 Crore have been given an option to file their Form GSTR-1 Statement & Form GSTR-3B return on a QTRLY basis. They also have an option to file B2B invoice details in Invoice Furnishing Facility (IFF) for months 1 & 2 (eg. Jan and Feb) of the quarter in order to pass on the credit, whereas the remaining invoices have to be declared in the QTRLY Form GSTR-1 of Month 3 (e.g. March). {With effect from 1st January 2021}

Our Recommendations: As we already know the limit of availing of the Input tax credit in respect of missed invoices have been reduced from 10% to 5% effective 01.01.2021. Thus, it is imperative for the large companies that have significant vendors under QRMP schemes that they should mandate their vendors to use the Invoice Furnishing Facility scheme. Basis the Invoice Furnishing Facility scheme, the inward supplies up to INR 1 Cr will be reflected in GSTR-2A before filing of GSTR-1 by the vendor. Thus, there will not be any unnecessary blockage of Input Tax Credit and it will also not put too much stress on the working capital of the large corporates.

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