Procedure for Filing Form CMP-08 Under GST: Due Dates and Penalties

In April 2019, a revised tax payment procedure was implemented for businesses under the GST composition scheme, aiming to streamline their compliance obligations. Form CMP-08, introduced in the same month and effective from the financial year 2019-2020, replaced the earlier quarterly GSTR-4 statement for composition taxpayers.

Understanding Form CMP-08

Form CMP-08 serves as both a statement and a challan for composition scheme taxpayers. This form is used to report the summary of their self-assessed quarterly tax liability and facilitate the corresponding tax payment. A composition dealer is an entity registered under the Goods and Services Tax (GST) composition scheme for supplying both goods and services. Besides filing Form CMP-08, these dealers are also required to submit their annual return through the updated Form GSTR-4 by April 30th after the conclusion of each financial year.

Eligibility for Filing Form CMP-08

Taxpayers who have chosen the composition scheme are mandated to file Form CMP-08 quarterly for tax deposits. The following categories of taxpayers, registered via CMP-02 (opting into the composition scheme), are eligible:

• Suppliers of goods, including manufacturers and retailers, with an annual aggregate turnover of up to Rs. 1.5 crore in the preceding financial year (Rs. 75 lakhs for special category states, excluding Jammu & Kashmir and Uttarakhand).

However, certain exclusions apply:

• Manufacturers of specific products like ice cream, edible ice (with or without cocoa), pan masala, tobacco, and its manufactured substitutes.
• Individuals involved in inter-state supplies.
• Individuals supplying goods exempt from GST.
• Casual or non-resident taxable persons.
• Businesses supplying goods through e-commerce operators.
• Service providers meeting the criteria specified in Notification Number 2/2019 Central Tax (Rate) dated March 7, 2019, provided their aggregate annual turnover in the previous financial year did not exceed Rs. 50 lakh.

Form CMP-08 Filing Deadline

The submission of Form CMP-08 is required quarterly, with the deadline set for the 18th day of the month immediately following the end of each quarter in a financial year. For instance, the filing deadline for the January-March 2024 quarter was April 18, 2024.

Consequences of Late Filing for Form CMP-08

If a taxpayer fails to submit Form CMP-08 by its designated due date, a late fee of Rs. 200 per day of delay is imposed. This fee consists of Rs. 100 per day under the Central Goods and Services Tax (CGST) Act and Rs. 100 per day under the State Goods and Services Tax (SGST) Act. The Integrated Goods and Services Tax (IGST) Act also mandates a late fee equivalent to the combined CGST and SGST late fees, totaling Rs. 200 per day of delay. These late charges are capped at a maximum of Rs. 5,000, calculated from the due date until the actual filing date. Furthermore, failure to file Form CMP-08 for two successive quarters results in the blocking of e-way bill generation. To reinstate e-way bill generation, taxpayers must submit an application in Form GST EWB 05 to their jurisdictional tax official and may also be required to file all outstanding forms for previous periods.

Steps for Taxpayers to Complete Form CMP-08

To complete Form CMP-08, a taxpayer must input several key details:

1. Enter GSTIN: The process begins with the taxpayer entering their Goods and Services Tax Identification Number (GSTIN).
2. Auto-filled Information: Upon GSTIN entry, essential information like the legal name and trade name will be automatically populated. The form will also update with an Application Reference Number (ARN) and the filing date once payment is successfully made.
3. Self-Assessed Tax Liability Summary: The form’s third section requires a summary of the self-assessed tax liability. Taxpayers need to furnish specifics regarding outward supplies subject to tax, inward supplies liable to tax under reverse charge, and import transactions. The corresponding tax amount due and any interest paid must also be declared.
4. Verification and Signature: The concluding step involves the taxpayer verifying all provided details and signing the form to confirm accuracy.

Important Considerations for Taxpayers:

• A taxpayer can submit a 'NIL' return if there is no tax liability for a particular quarter. A Nil CMP-08 can be filed conveniently via SMS.
• Failure to meet the filing deadline will result in the taxpayer being subject to both interest charges and penalties.
• Declared tax liabilities should encompass any adjustments for advances, credit notes, debit notes, or other rectifications.