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Re: Payment of tax, interest, penalty and other amounts [section 35]

Payment, topic of this communication, of Tax and other amount(s) under the Act could be through ITC and / or to Bank through electronic or other modes.

It is provided that all liabilities, payments and credits shall be recorded and accounted by debit or credit to, through appropriate transaction or document, the following Ledgers (to be maintained on Common Portal):

Electronic Tax liability Register of taxpayer [section 35 (7)] [Form GST PMT-1]
(in 2 parts: Return related liabilities and Other liabilities; containing debits for the liability and credit for payment through cash or ITC)
Electronic Credit Ledger of Taxpayer [section 35 (1)] [Form GST PMT-2]
(containing credits on the basis of return and debits for payment by using ITC)
Electronic Cash Ledger of Taxpayer [section 35 (1)] [Form GST PMT-3]
(containing payments through banking channels or cash and debits for various payments)

The details and particulars, inter alia, require nature of transaction and reference thereof for recording transactions in the respective Ledgers; otherwise, details are evident from Forms and hereafter only nature of debits and credits are illustrated in following illustrative Ledger accounts:

Electronic Cash Ledger

Debit	Credit
Use for Payment of [Section 35(3)]	Nature of Deposit
· Tax · Interest · Penalty · Fees ·Other amount	Deposit in Authorised Bank towards [through specified mode (See procedure)] · Tax · Interest · Penalty · Fees ·Other amount
Refund claimed	Refund rejected (see note 2)
Balance [Eligible for refund] [Section 35(6)]

Electronic Credit Ledger

Debit	Credit
Use for Payment of [Section 35(3)]	Nature of Deposit
Tax	ITC as per self-assessed return

Refund claimed of unutilised ITC	Rejection of refund claim of unutilised ITC
Balance [Eligible for refund] [Section 35(6)]

CGST account
Use for Payment of	Nature of Deposit
CGST	CGST ITC as per self-assessed return
Balance, if any, IGST

Balance [Eligible for refund] [Section 35(6)]

SGST account
Use for Payment of	Nature of Deposit
SGST	SGST ITC as per self-assessed return
Balance, if any, IGST

Balance [Eligible for refund] [Section 35(6)]

IGST account
Use for Payment of	Nature of Deposit
IGST	IGST ITC as per self-assessed return
CGST
Balance, if any, SGST

Balance [Eligible for refund] [Section 35(b)]

Electronics Tax Liability Register

Debit	Credit
· Tax · interest · penalty · any other amount payable, as per Return filed	From Electronic Credit Ledger (only for payment of Tax and not any other amount) From electronic Cash Ledger
· Tax · Interest · penalty · any other amount payable (determined by Proper Officer under the Act or ascertained by RTP)
Tax or interest payable due to mismatch under different provisions (section 29 / 29A /43C)
Interest, as may accrue from time to time
Tax deducted	From Electronic Cash Ledger
Tax collected	From Electronic Cash Ledger
Composition payment	From Electronic Cash Ledger
Interest, penalty, fee or any other amount (apparently, relating to above)	From Electronic Cash Ledger
	Relief given by Appellate Authority (to that extent corresponding amount of tax, penalty, etc listed in "Debit" would get reduced through credit)
	Reduction in amount of penalty (listed in Debit column), if RTP makes payment of tax, interest and penalty as per show cause notice or demand order

Interest on delayed payment

For delayed payment or excess / undue ITC used, interest is payable at prescribed rate.

Procedure for payment [Rule 3]

RTP shall generate challan in Form GST PMT-4 on Common Portal giving details of amount of tax or interest or penalty or fees or any other amount to be paid (challan shall be valid for a period of 15 days);
Deposit through following:
- Internet banking through authorised banks; or
- credit card or debit card (registered with Common portal through authorised bank); or
- on the counter payment (OTC) through authorised bank (for deposit up to Rs 10,000, per challan, per period, by cash or check or demand draft).
Restriction on limitation about OTC payment will not apply, where:
- deposit is made by government departments; or
- deposit is made by notified persons; or
Proper Officer recovers outstanding dues including recovery through attachment or sale of properties; or
- Proper Officer collects amount during any investigation or enforcement activity or any ad hoc deposit.
Commission, if any, payable for payment shall be borne by RTP.
Non-RTP can make payment based on Temporary Identification Number generated by Proper Officer through common portal; it's details shall be recorded in Register in Form GST PMT-5 on Common Portal.
If payment is made by NEFT or RTGS, mandate form (valid for 15 days from challan generation date) generated along with challan should be submitted to bank.
On credit of amount to Government account with authorised bank, "Challan Identification Number" (CIN), generated by collecting bank, shall be indicated in challan (if CIN is not generated, RTP or other person may represent electronically in Form GST PMT-6, through Common Portal, to bank or electronic gateway).
On receipt of CIN, deposit shall be credited to Electronic Cash Ledger of RTP and Common Portal shall make available a receipt thereof

Tax deducted or collected [Rule 3 (8)]

Tax deducted or collected (under the Act) and claimed in Form GSTR-2, by RTP, shall be credited to his electronic Cash Ledger.

Identification number for each transaction [Rule 4]

A unique identification number (UIN) should be generated at Common portal for each debit or credit to Electronic Cash or Credit Ledger; UIN about discharge of liability should be indicated in corresponding entry in Electronic tax liability Register ("the Register"); UIN shall be generated, at Common Portal, for each credit (other than for discharge of liability).

Business Impact and actions

Maintenance of ledgers (on Common Portal) would facilitate information about liability, balance and the like.
Reconciliations thereof from time to time would be necessary. In case of any 'mismatch' immediate action can be taken.
For effective payment, preparation in advance would be a must.
Any delay may result in delayed return affecting recipients and rating.

We shall be obliged for feedback.