Composition Returns: CMP-08 and GSTR-4

A composition taxpayer files fewer returns than anyone else on GST: four quarterly statements and one annual return. The two forms work differently.

• CMP-08 carries the tax. It has no late fee, but it gates two things. A taxpayer who misses two in a row cannot generate e-way bills, and no annual return can be filed until every one of them is in.
• GSTR-4 carries the detail of purchases. Its due date moved from 30 April to 30 June in 2024, and the portal now fills much of it from suppliers’ filings.

Joining and leaving the scheme, its rates and its conditions are covered in Opting In and Out of the Composition Scheme. This guide covers the returns filed while in the scheme and on the way out.

The two forms and their law

Section 39(2) requires a person paying tax under section 10 to file a return “for each financial year or part thereof”, covering turnover in the State, inward supplies, tax payable and tax paid. The second proviso to section 39(7) requires the tax to be paid quarterly, “in such form and manner, and within such time, as may be prescribed”.

Rule 62(1) prescribes both:

• “(i) furnish a statement, every quarter or, as the case may be, part thereof, containing the details of payment of self-assessed tax in FORM GST CMP-08, till the 18th day of the month succeeding such quarter”
• “(ii) furnish a return for every financial year or, as the case may be, part thereof in FORM GSTR-4”

Rule 62(2) requires the tax and interest to be paid “by debiting the electronic cash ledger”. A composition taxpayer takes no input tax credit, so there is nothing else to pay from.

The annual return is GSTR-4, not GSTR-9. Rule 80(1) still names FORM GSTR-9A for composition taxpayers, but the portal’s GSTR-9A FAQ says GSTR-9A “is not applicable for the FY 2019-20 and onwards”.

Due dates

Form	Due date	Source
CMP-08, April to June	18 July	Rule 62(1)(i)
CMP-08, July to September	18 October	Rule 62(1)(i)
CMP-08, October to December	18 January	Rule 62(1)(i)
CMP-08, January to March	18 April	Rule 62(1)(i)
GSTR-4 for 2024-25 onwards	30 June after the year	Proviso to rule 62(1), inserted by Notification No. 12/2024-Central Tax
GSTR-4 up to 2023-24	30 April after the year	Rule 62(1)(ii)

The CMP-08 for July to September 2026 is therefore due on 18 October 2026. The GSTR-4 for 2026-27 is due on 30 June 2027.

The two dates are not staggered by State. The Government has extended them occasionally by notification. For example, Notification No. 11/2022-Central Tax extended the CMP-08 for April to June 2022 to 31 July 2022.

Notification No. 12/2024-Central Tax also amended instruction 2 to the form for the new date. The portal’s GSTR-4 FAQ has not been updated: it still describes the due date as the 30th of “the month succeeding the financial year”.

CMP-08: what goes in it

CMP-08 is a one-table statement. Table 3 has five rows:

1. outward supplies, including exempt supplies
2. inward supplies attracting reverse charge, including import of services
3. tax payable (rows 1 and 2)
4. interest payable, if any
5. tax and interest paid

The instructions to the form allow figures to be reported net of advances, credit notes, debit notes and corrections. A negative total is carried forward to the next quarter. A “Nil” statement is filed for a quarter with no liability.

What to have ready for CMP-08:

Item	Where it comes from
Turnover of the quarter, including exempt supplies, at the composition rate	Books (sales register, bills of supply)
Inward supplies under reverse charge, including import of services	Books (purchase register)
Credit and debit notes and advances to adjust	Books
Negative liability carried forward from the last quarter	Portal (shown in the statement)
Cash ledger balance, or funds for a challan	Portal

Portal steps. The portal’s CMP-08 manual and FAQ describe them:

1. The filer opens Services > Returns > Returns Dashboard and selects the year and quarter.
2. For a nil statement, the filer ticks “File Nil GST CMP-08”. A nil statement can also be filed by SMS to 14409, in the form NIL C8 <GSTIN> <period>, confirmed with CNF C8 <code>. See Filing Nil Returns by SMS or on the Portal.
3. Otherwise the filer enters Table 3 and clicks PROCEED TO FILE. The portal then checks two things. First, the statements for earlier quarters must be filed. Second, for a person who opted in from regular tax, the last GSTR-3B due as a normal taxpayer must be filed.
4. The portal checks turnover against the threshold for the chosen category. If the year’s turnover so far exceeds it, the portal does not allow filing. An alert appears in My Alerts once turnover reaches 80 per cent of the limit.
5. The tax is paid from the cash ledger. If the balance falls short, a challan is created from the same screen. The FAQ states that CMP-08 liability “can be paid only through cash and not through ITC”.
6. The filer files with DSC, EVC or a single-time authentication key generated in the “GST Secure OTP” app. The portal issues an ARN.

CMP-08: no late fee, but interest and consequences

The portal’s FAQ answers the question directly: “there is no late fee for delayed filing of Form GST CMP-08”. This follows from the Act. Section 47(1) imposes late fee for details under section 37 and returns under sections 39, 45 and 52. CMP-08 is the payment statement under the second proviso to section 39(7), not the return.

Late payment does attract interest under section 50(1), at 18 per cent a year (Notification No. 13/2017-Central Tax). Instruction 5 to the form says “Interest shall be leviable if payment is made after the due date”, and row 4 of Table 3 is where it is declared.

Not filing has three consequences.

E-way bills are blocked. Rule 138E(a) bars anyone from generating Part A of an e-way bill for outward movement of goods of a composition taxpayer who “has Not furnished the statement in FORM GST CMP-08 for two consecutive quarters”. The bar covers the consignor, consignee, transporter, e-commerce operator and courier alike.

The portal’s FAQ says generation is unblocked automatically once the statements are filed and the default falls below two tax periods. Alternatively, the taxpayer can apply to the jurisdictional officer in FORM GST EWB-05. The officer decides by an order in EWB-06, after a hearing if the request is to be refused (rule 138E, first and second provisos).

GSTR-4 cannot be filed. The portal enables the annual return only after every CMP-08 for the year is filed. A later CMP-08 cannot be filed while an earlier one is outstanding.

Suspension and cancellation follow from GSTR-4. No rule suspends a registration for missing CMP-08 alone. But section 29(2)(b) allows cancellation where a composition taxpayer “has not furnished the return for a financial year beyond three months from the due date”. Under rule 21A(2), the officer may suspend the registration while cancellation proceedings are pending. Rule 138E(d) also bars e-way bills for a person whose registration is suspended under rule 21A, though the portal’s published material describes blocking only for unfiled GSTR-3B returns and CMP-08 statements; When E-Way Bill Generation Is Blocked: Rule 138E sets out the position. The procedure is in Responding to a Notice Proposing Cancellation.

GSTR-4: the tables

FORM GSTR-4 has these tables:

Table	Content	How filled
3(a)	Aggregate turnover of the preceding year	Typed in. The portal’s FAQ says the filer cannot proceed without it, and enters zero if newly registered
4A	Inward supplies from registered suppliers, other than reverse charge	Auto-drafted from suppliers’ filings, editable
4B	Inward supplies from registered suppliers under reverse charge	Auto-drafted, editable
4C	Inward supplies from unregistered suppliers	Typed in
4D	Import of services	Typed in
5	Summary of self-assessed liability as declared in the year’s CMP-08s	Auto-filled from CMP-08, not editable
6	Rate-wise outward supplies, and inward supplies under reverse charge	Outward supplies typed in. Reverse-charge rows filled from 4B to 4D after PROCEED TO FILE
7	TDS and TCS credit received	Auto-filled from deductors’ and operators’ filings, not editable
8	Tax, interest and late fee payable and paid	Tax and late fee computed; interest typed in
9	Refund claimed from the electronic cash ledger	Typed in

Rule 62(3) requires the return to include “invoice-wise inter-State and intra-State inward supplies received from registered and un-registered persons”. It also requires “consolidated details of outward supplies made”.

Inward supplies are now largely pre-filled. Under rule 60(1), suppliers’ GSTR-1 data is made available to a composition taxpayer in FORM GSTR-4A. Notification No. 12/2024-Central Tax added GSTR-1A to its sources, so GSTR-4A is now drafted from GSTR-1, GSTR-1A, GSTR-5 and GSTR-7.

The portal’s GSTR-4 manual says that “from financial year 2024-25 onwards, the values from GSTR-1A shall also be auto drafted in table 4A, 4B”. It notes that a purchase whose place of supply is outside the taxpayer’s State is not auto-populated. From 2024-25, inward supplies other than reverse-charge supplies in Table 4C are reported as one consolidated row.

Table 6 is the real annual return of turnover. The portal computes the balance payable in four steps: tax on the Table 6 outward supplies, plus tax on reverse-charge purchases, less the tax already paid through CMP-08 (Table 5), less any negative liability carried forward. For 2024-25 onwards, a non-editable table compares Table 5 with Table 6. The manual says the portal warns if the outward liability in Table 6 is nil or well below what the CMP-08s declared.

What to have ready for GSTR-4:

Item	Where it comes from
All four CMP-08s for the year, filed	Portal
Preceding year’s aggregate turnover	Previous returns
Purchase register by supplier, with GSTIN, invoice, rate and tax; reverse-charge and unregistered purchases; imports of services	Books
GSTR-4A for the year, to check against the purchase register	Portal
Rate-wise turnover for the year, net of credit notes and advances	Books
TDS and TCS credited during the year	Portal (cash ledger)
Cash ledger balance, or funds for a challan	Portal

Portal steps. The portal’s GSTR-4 annual return manual describes them:

1. The filer opens Services > Returns > Annual Return, selects the year and clicks PREPARE ONLINE on the GSTR-4 tile. The tile is enabled only once all the year’s CMP-08s are filed.
2. The filer enters the preceding year’s aggregate turnover and saves.
3. For a nil return, the filer ticks “File Nil GSTR4”. This is possible only where there were no outward or inward supplies, no other liability, and every CMP-08 for the year was nil.
4. Otherwise the filer reviews and edits Tables 4A and 4B, adds 4C and 4D, and enters outward supplies in Table 6.
5. The filer clicks Compute Liabilities, downloads the draft summary, and clicks PROCEED TO FILE.
6. In Table 8 the portal shows the balance tax and any late fee, and the filer enters interest. Payment is from the cash ledger only; the FAQ is explicit.
7. The filer ticks the declaration, selects the authorised signatory and files with DSC or EVC.

Signing

Rule 26 allows a digital signature certificate, an e-signature or a notified mode such as EVC. Rule 26(2) says who signs for an individual, a firm, a company and so on. The portal’s FAQs list DSC and EVC for GSTR-4, and DSC, EVC or the authentication key for CMP-08.

GSTR-4: late fee and the three-year bar

Section 47(1) sets the statutory late fee at Rs 100 a day up to Rs 5,000 under the CGST Act. Notification No. 73/2017-Central Tax, as amended by Notification No. 21/2021-Central Tax, reduces it as follows:

GSTR-4	Late fee under the CGST Act
Central tax payable is nil	Rs 10 a day, up to Rs 250 (2021-22 onwards)
Any other case	Rs 25 a day, up to Rs 1,000 (2021-22 onwards)

A late fee is also levied under the State or Union territory Act. The portal computes both and shows them in Table 8. It does not allow filing until the fee is paid, and that includes a nil return.

Notification No. 02/2023-Central Tax gave an amnesty for older years. For the quarters of 2017-18 and 2018-19 and the years 2019-20 to 2021-22, the fee was capped at Rs 250, or waived entirely for a nil return, if the GSTR-4 was filed between 1 April and 31 August 2023. The closing date was extended to 31 August by Notification No. 22/2023-Central Tax. That window has closed.

Section 39(11) bars a return filed more than three years after its due date, and the portal lists GSTR-4 among the forms it bars. The GSTR-4 for 2022-23, due on 30 April 2023, could not be filed after 30 April 2026. CMP-08 is not on the portal’s list. See Late Returns: Late Fee, Interest, the Three-Year Bar and Notices.

Returns on the way out of the scheme

A person who leaves the scheme by filing FORM GST CMP-04, or whose option is withdrawn by the officer, still owes the composition returns for the part of the year spent in the scheme. Rule 62(5) requires:

• a CMP-08 for the period under composition, “till the 18th day of the month succeeding the quarter in which the date of withdrawal falls”
• a GSTR-4 for that period

For the GSTR-4, rule 62(5) still says “till the thirtieth day of April following the end of the financial year during which such withdrawal falls”. The 2024 amendment that moved the date to 30 June added a proviso to sub-rule (1) only, and left sub-rule (5) unchanged. The portal’s FAQ treats the GSTR-4 of a person who opted out as the ordinary annual return “for the period during which you remained under the composition scheme”.

From the date of withdrawal, the person files GSTR-1 and GSTR-3B as a normal taxpayer. Credit on stock held on that date is claimed in FORM GST ITC-01 within thirty days, under rules 6(6) and 40. That is covered in Opting In and Out of the Composition Scheme. If aggregate turnover for the year exceeds Rs 2 crore, the person also files GSTR-9 for the period under normal tax, as explained in Filing the Annual Return, GSTR-9.

A composition taxpayer whose registration is cancelled files no final return (GSTR-10). Section 45 applies only to persons filing under section 39(1). The CMP-08s and the GSTR-4 for the part year remain due.

After filing

Neither form can be revised. The FAQs say so in terms: “Form GST CMP-08 once filed, cannot be revised”, and “you cannot revise Form GSTR-4 (Annual Return) after filing”. An error in a CMP-08 is adjusted in a later quarter’s statement. The instructions allow adjustments, and a negative balance carries forward. An error found after GSTR-4 is filed can only be dealt with by paying through DRC-03. The options are in Correcting Mistakes in Returns.

The procedure in order

1. Each quarter, total the turnover (including exempt supplies) and the reverse-charge purchases, and adjust for credit notes and advances.
2. File CMP-08 by the 18th of the month after the quarter, paying the tax from the cash ledger, or file a nil statement online or by SMS.
3. Pay interest on any tax paid late. Avoid missing two quarters in a row, which blocks e-way bills.
4. After the year, check GSTR-4A against the purchase register.
5. File GSTR-4 by 30 June. Review the pre-filled Tables 4A and 4B, add 4C and 4D, enter rate-wise turnover in Table 6, and pay any balance, interest and late fee in cash.
6. Sign with DSC or EVC (or, for CMP-08, the GST Secure OTP key), and keep the ARNs.
7. On leaving the scheme, file the CMP-08 for the quarter of withdrawal and a GSTR-4 for the period under composition. Then move to GSTR-1 and GSTR-3B, and claim credit on stock in ITC-01 within thirty days.

The next guide covers the returns of non-resident taxable persons and OIDAR suppliers: GSTR-5 and GSTR-5A.