NIL GSTR-1 filed under QRMP despite reporting sales in GSTR-3B (B2C supplies)

[Bishal]

A taxpayer registered under the QRMP scheme since FY 2020-21 has always filed NIL GSTR-1 for all quarters, but has correctly disclosed B2C outward supplies and paid the applicable GST in GSTR-3B for the respective months.

There are no B2B transactions involved, so no recipient ITC is affected. The error is purely procedural, but it has resulted in a mismatch between GSTR-1 and GSTR-3B for multiple past years.

What is the best possible remedy now, considering:

• The statutory time limit for rectifying GSTR-1 for FY 2020-21 and 2021-22 has already lapsed under Section 37(4) of the CGST Act.

• The taxpayer wants to correct records to avoid mismatch notices and future disputes.

• All taxes have already been paid, and there is no revenue loss to the Government.

Experts are requested to advise on:

1. Whether old B2C supplies can still be reported in the current GSTR-1, and if so, the correct reporting method.

2. Any departmental intimation or reconciliation statement that should be filed to avoid notices.

AI Summary

Taxpayer faces GST mismatch due to NIL GSTR-1 filings under QRMP scheme; manual correction advised to avoid penalties A taxpayer under the QRMP scheme filed NIL GSTR-1 returns despite reporting and paying GST on B2C sales in GSTR-3B, causing mismatches for past years. Since the statutory time limit for amending GSTR-1 for those years has expired, the taxpayer seeks to correct records to avoid notices and disputes. Experts advise that the department may view the omission as irregular and potentially propose penalties for non-filing of GSTR-1. Although all taxes were paid and no revenue loss occurred, the recommended remedy is to manually submit the sales details to the local GST officer to address the discrepancy and mitigate enforcement action. Reporting old B2C supplies in the current GSTR-1 is not straightforward due to time limits, so direct departmental communication and reconciliation are advised to prevent future notices.