Initiatives in GST for Small and Medium Enterprises

Through a number of Act provisions, small taxpayers are generally given preferential treatment under the GST Law.

(a) For intrastate and interstate service provision up to R 20 Lakh (R 10 Lakh for the states of Manipur, Mizoram, Nagaland, and Tripura), there is no registration need.

(a) Effective April 1, 2019, there is no need for registration for intra-state supply of commodities up to ₹ 40 Lakh (₹ 20 Lakh in the states of Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Puducherry, Sikkim, Telangana, Tripura, and Uttarakhand).

(c) There is no tax on payments made in advance for the supply of goods.




(d) A composition plan has been developed for small business owners who supply both restaurant services and commodities. According to the plan, an individual whose turnover does not exceed ₹ 1.5 Cr (₹ 75 Lakh in the states of Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Sikkim, Tripura, and Uttarakhand) must file an annual return and make quarterly payments.

(e) A composition strategy for service providers has been developed. A person having a turnover up to ₹ 50 lakh is required by the plan to file annual returns and make quarterly payments starting in FY 2019–20, and to pay tax equal to 6% of that turnover.

(f) Composition taxpayers are required to make quarterly tax payments. These taxpayers are exempt from the need to keep comprehensive accounts and records, and they are required to file quarterly challans and a single annual return in lieu of monthly statements and a return.

(g) Small taxpayers shall receive free accounting and billing software from GSTN.

(h) At the zonal and state levels, Grievance Redressal Committees (GRCs) have been established with CGST and SGST authorities, as well as trade and industry representatives and other GST stakeholders (such as GST practitioners and GSTN, among others). At the state and zonal levels, these committees handle complaints from taxpayers that are either specific or generic in character.

New GST and Policy Measures Aimed at the MSME Industry

(a) The Small Taxpayer QRMP Program: Beginning on January 1, 2021, small taxpayers with aggregate annual turnover up to ₹ 5 Cr will have the option to file quarterly reports rather than monthly filings under the quarterly filing and monthly payment (QRMP) system. For such taxpayers, the number of returns in a year has decreased from 24 previously to 8. Approximately 89% of taxpayers who have registered for GST are eligible for this service.

(b) The upper maximum on late fees has been adjusted to correspond with taxpayer turnover and tax liability in order to lessen the burden of late fees on smaller taxpayers.

The following late fee is capped per return for failure to furnish FORM GSTR-3B and FORM GSTR-1:

(i) The maximum late fee for taxpayers with no tax due on Form GSTR-3B or no outward supplies on Form GSTR-1 is ₹ 500 (₹ 250 CGST + ₹ 250 SGST).

(ii) For additional taxpayers:

◊ The maximum late fee for taxpayers with Aggregate Annual Turnover (AATO) of ₹ 1.5 Cr in the previous year was ₹ 2,000 (₹ 1,000 CGST + ₹ 1,000 SGST);

◊ The maximum late fee for taxpayers with Aggregate Annual Turnover (AATO) in the previous year ranging from ₹ 1.5 Cr to ₹ 5 Cr was capped at ₹ 5,000/- (₹ 2,500/- CGST + ₹ 2,500/- SGST);

◊ The maximum late fee for taxpayers with an aggregate annual turnover (AATO) of more than ₹ 5 Cr in the previous year was ₹ 10,000/- (₹ 5,000/- CGST + ₹ 5,000/- SGST).



•If there is no tax liability on the return, the late charge for composition taxpayers is limited to ₹ 500/-(₹ 250/-CGST + ₹ 250/-SGST) per return; if not, it is ₹2,000/-(₹ 1,000/-CGST + ₹ 1,000/-SGST) per return.

• The late charge for submitting Form GSTR-7 after the deadline has been lowered to ₹ 50/-per day (₹ 25/-CGST + ₹ 25/-SGST), with a maximum of ₹ 2,000/-(₹ 1,000/-CGST + ₹ 1,000/-SGST) per return.

(c) For the months of March, April, and May of 2021, the following COVID-related relaxations have been made available to smaller taxpayers with AATOs up to ₹ 5 Cr:

• Interest Decrease:

9% interest for the following 45 days, 30 days, and 15 days for the months of March 2021, April 2021, and May 2021, after the first 15 days after the tax payment deadline.

• No late fee is charged:

For tax periods ending in March 2021, there will be no late fee for 60 days for returns in FORM GSTR-3B that are submitted after the deadline. The same was excluded for 45 days in April 2021 and 30 days in May 2021, respectively.

(d) Making the Annual Return Simpler:

• By virtue of Notification No. 32/2023-Central Tax dated July 31, 2023, taxpayers with Aggregate Annual Turnover up to ₹. 2 Cr are exempt from making an annual return in FORM GSTR-9 for FY 2022–2023.

• As per Notification No. 14/2022-Central Tax dated 05.07.2022, taxpayers with Aggregate Annual Turnover up to ₹ 2 Cr are exempt from filing annual returns in FORM GSTR-9 for FY 2021–2022.


• Notification has been given of changes made to sections 35 and 44 of the CGST Act by the Finance Act of 2021. Due to the fact that taxpayers can now self-certify the reconciliation statement rather to having it approved by a chartered accountant, the compliance requirement for providing reconciliation statements in FORM GSTR-9C has been loosened. From FY 2020–21 onward, the Annual Return is subject to this modification.

• For taxpayers with aggregate annual turnover up to ₹ 2 Cr, making an annual return in Form GSTR-9 for FY 2020–21 is now optional.

• Taxpayers with an aggregate annual turnover exceeding ₹ 5 Cr are required to file the reconciliation statement in FORM GSTR-9C for the fiscal year 2020–21.

(e) Starting on July 1, 2017, interest will be charged on net cash liability. The 45th meeting of the Council decided to apply the same ruling to ineligible ITC that was obtained and used.



(f) The following changes have been made to the CGST Rules’ Rule 45(3) regarding the requirement to file FORM GST ITC-04:

• Once every six months, taxpayers whose aggregate annual revenue in the previous fiscal year exceeded ₹5 Cr are required to provide FORM ITC-04;


Read More: Understanding Advance Tax and Its Applicability


• Taxpayers who had an aggregate annual revenue of up to ₹ 5 Cr in the previous fiscal year are required to submit FORM ITC-04 on a yearly basis.

(e) Clarifications pertaining to exports have been released in Circulars Nos. 159 and 161, both dated September 20, 2021. This has eliminated doubt over the meaning of intermediary services’ scope and the export of services as a whole.


RBI to Launch First Pilot of Retail Digital Rupee on 1st December 2022

Operationalization of Central Bank Digital Currency – Retail (e₹-R) Pilot

The Reserve Bank announces the launch of the first pilot for retail digital Rupee (e₹-R) on December 01, 2022. It may be recalled that RBI had, in a Press Release dated October 31, 2022, indicated that the pilot in e₹-R would commence in a month’s time.

2. The closed user group (CUG), which consists of participating customers and retailers, would cover a few specific regions in the trial. The e-R would take the shape of a digital token that stands in for money. It would be distributed in the same denominations that coins and paper money are now distributed in. It would be spread by means of middlemen, namely banks.




Through a digital wallet provided by the participating banks and kept on mobile phones or other devices, users will be able to conduct transactions with e-R. Both person-to-person (P2P) and person-to-merchant transactions are possible (P2M). QR codes that are displayed at retail places can be used to make payments to retailers.

The e-R would provide characteristics of actual money, such as trust, safety, and settlement finality. As in the case of cash, it will not earn any interest and can be converted to other forms of money, like deposits with banks.

3. The real-time pilot will evaluate the sturdiness of the complete creation, distribution, and retail use of digital rupees. Based on the lessons learned from this pilot, other aspects and uses of the e-R token and architecture will be evaluated in further pilots.




4. Eight banks have been chosen to take part in this pilot project in phases. Four banks—State Bank of India, ICICI Bank, Yes Bank, and IDFC Initial Bank—will launch the first phase in four locations throughout the nation. Following the initial four banks, this pilot will also include the Bank of Baroda, Union Bank of India, HDFC Bank, and Kotak Mahindra Bank. Mumbai, New Delhi, Bengaluru, and Bhubaneswar would be the first four cities the pilot would cover.


Read More: UDIN- Do’s & Don’t!


Later, Ahmedabad, Gangtok, Guwahati, Hyderabad, Indore, Kochi, Lucknow, Patna, and Shimla would also be included. As needed, the pilot’s scope may be gradually expanded to cover additional banks, users, and locations.

GST search operations, No coercion is used and dues are paid at all times.

GST search operations, No coercion is used and dues are paid at all times.

It also instructed chief commissioners to take “severe disciplinary action” against officers who used force or coercion to collect the tax due amount deposited during a search, inspection, or investigation, according to an instruction.


The Goods and Services Tax (GST) investigation wing has issued instructions stating that taxpayers can pay tax dues at any stage during the search operation, citing “alleged use of force and coercion by officers for making recovery” during search, inspection, and investigation, as well as subsequent court cases.


It also instructed chief commissioners to take “severe disciplinary action” against officers who used force or coercion to collect the tax due amount deposited during a search, inspection, or investigation, according to an instruction.

“It is clarified that there may not be any conditions that require’recovery’ of tax dues during the course of a search, inspection, or investigation.” “However, there is no ban on taxpayers making voluntary contributions based on ascertainment of their responsibility on non-payment/short payment of taxes before or at any stage of such proceedings,” the GST investigation wing stated.


It goes on to say that the tax officer shall advise taxpayers about the terms of voluntary tax payments via DRC-03.

There have been several instances where GST has been deposited into effect by summoning senior office bearers such as directors or promoters of the company. This circular tries to prevent this, however given the existence of the DRC-03 method for depositing tax, the officials may still use indirect coercion to get the assessee to pay up. There have also been instances of bank accounts being frozen, which has resulted in unnecessary hardship for the taxpayer.


“While the circular will decrease the department’s use of compulsion to obtain the tax deposited during the inquiry process,” EY India tax partner Bipin Sapra said, “considering that the officers have authority to summon and block bank accounts, any direct direction may be of little use.”