Library / Goods and Services Tax: The Professional's Master Guide

25. Payment of Tax, Interest, TDS and TCS (Sections 49 to 53)

Tax is paid through three electronic ledgers maintained on the portal (section 49). The electronic cash ledger is credited by deposits through PMT-06 challans. The electronic credit ledger holds ITC. The electronic liability register records all dues, including demands.

25.1 Cash ledger, challans and PMT-09

A PMT-06 challan is valid for 15 days. Payment by net banking, UPI, card, NEFT or RTGS (or over the counter up to Rs. 10,000) credits the cash ledger under the major head (IGST, CGST, SGST, cess) and minor head (tax, interest, penalty, fee). A balance in the wrong head can be moved through PMT-09, and since the Finance Act, 2022 to a distinct person with the same PAN, if no demand is unpaid. The cash ledger can pay any liability; the credit ledger can pay only output tax.

25.2 Order of utilisation of ITC

Sections 49(5) and 49A and rule 88A lay down the order: IGST credit is used first against IGST liability, and the balance may then be used against CGST and SGST in any order. CGST and SGST credits are used only after IGST credit is exhausted, each against its own head and then IGST; they never cross. From February 2026 the portal lets the IGST balance be split between CGST and SGST in any proportion, avoiding cash payment in one head while credit lies idle in the other.

Illustration 138: Set-off to minimise cash

Output tax of Arora Industries for a month: IGST Rs. 50,000, CGST Rs. 80,000, SGST Rs. 80,000. ITC: IGST Rs. 1,20,000, CGST Rs. 30,000, SGST Rs. 50,000.

Step 1: IGST credit against IGST liability: Rs. 50,000. IGST credit left = Rs. 70,000.

Step 2: Balance IGST credit applied Rs. 50,000 to CGST and Rs. 20,000 to SGST. CGST left = Rs. 30,000; SGST left = Rs. 60,000.

Step 3: CGST credit Rs. 30,000 pays CGST fully. SGST credit Rs. 50,000 pays SGST, leaving Rs. 10,000.

Step 4: Cash payable = Rs. 10,000 (SGST).

Comparison: an equal split of Rs. 35,000 each leaves CGST of Rs. 15,000 (Rs. 80,000 minus Rs. 35,000 minus Rs. 30,000) payable in cash with Rs. 5,000 of SGST credit idle, costing Rs. 5,000 more cash.

Tax payable under reverse charge must be paid in cash: the credit ledger can pay only "output tax" (section 49(4)), and output tax excludes tax payable under reverse charge (section 2(82)). Rule 86B also requires registered persons whose taxable supplies exceed Rs. 50 lakh in a month to pay at least 1% of output tax in cash, subject to exceptions.

25.3 Interest under section 50

Interest at 18% is payable under section 50(1) on tax paid after the due date, for the period of delay. Under the retrospective amendment from 1 July 2017 and rule 88B, it is on the net tax paid in cash, unless the return is filed after proceedings under section 73, 74 or 74A begin. From 10 July 2024 an amount deposited in the cash ledger on or before the due date and kept there until it is debited in the return is excluded from interest. Under section 50(3), interest at 18% is payable on ITC wrongly availed and utilised, from the date of utilisation to the date of reversal or payment. Credit is treated as utilised when the credit ledger balance falls below the wrong credit, to the extent of the fall (rule 88B(3)).

Illustration 139: Interest on delayed GSTR-3B

Bose Chemicals files GSTR-3B for July 2026 (due 20 August 2026) on 5 September 2026. Liability Rs. 3,00,000, ITC used Rs. 2,20,000, cash Rs. 80,000.

Step 1: Delay = 21 August to 5 September 2026 = 16 days.

Step 2: Interest = Rs. 80,000 x 18% x 16 / 365 = Rs. 631.

Variation: Rs. 30,000 had been deposited in the cash ledger on 18 August and stayed there till filing. Interest is only on Rs. 50,000: Rs. 50,000 x 18% x 16 / 365 = Rs. 395.

Illustration 140: Interest on wrong ITC utilised

Chopra Garments wrongly availed ITC of Rs. 1,00,000 in GSTR-3B for March 2026, filed on 20 April 2026. On 20 May 2026 its credit ledger balance fell to Rs. 60,000. It reversed the credit through DRC-03 on 19 July 2026.

Step 1: Utilised = Rs. 1,00,000 minus Rs. 60,000 = Rs. 40,000, from 20 May 2026.

Step 2: Period = 21 May to 19 July 2026 = 60 days.

Step 3: Interest = Rs. 40,000 x 18% x 60 / 365 = Rs. 1,184. No interest arises on the Rs. 60,000 that was never used.

25.4 DRC-03 and DRC-03A

Voluntary payments on self-detection, in audit or against a notice are made through DRC-03. Such a payment does not by itself close a later demand. DRC-03A, introduced in 2024, links the DRC-03 payment to the demand order; without it, recovery may start on a demand already paid.

25.5 Tax deduction at source (section 51)

Government departments, local authorities, Government agencies and notified bodies (such as public sector undertakings and bodies with 51% or more Government shareholding) must deduct 2% (1% CGST + 1% SGST, or 2% IGST) from payments to suppliers of taxable goods or services where the total value of supply under a contract exceeds Rs. 2.5 lakh (excluding tax). No deduction is made where the supplier's location and the place of supply are in a State other than the recipient's State of registration. The deductor files GSTR-7 by the 10th; the supplier accepts the credit into his cash ledger.

Illustration 141: TDS on a Government contract

A municipal corporation in Gujarat awards a road repair contract to Parmar Builders, Surat, for Rs. 10,00,000 plus GST at 18% (Rs. 1,80,000).

Step 1: Contract value excluding tax (Rs. 10,00,000) exceeds Rs. 2.5 lakh, so TDS applies.

Step 2: TDS = 2% of Rs. 10,00,000 = Rs. 20,000 (CGST Rs. 10,000 + SGST Rs. 10,000).

Step 3: Payment to Parmar Builders = Rs. 11,80,000 minus Rs. 20,000 = Rs. 11,60,000.

25.6 Tax collection at source (section 52)

An e-commerce operator collecting consideration for supplies made through it by other suppliers must collect tax at 0.5% (0.25% CGST + 0.25% SGST, or 0.5% IGST) of the net value of taxable supplies, from 10 July 2024 (1% earlier). Net value is taxable supplies less returns, and excludes supplies on which the operator itself pays tax under section 9(5). The operator files GSTR-8 by the 10th; sellers accept the TCS into their cash ledger.

Illustration 142: TCS by an e-commerce operator

Sellers on ShopKart, registered in Maharashtra, make taxable supplies of Rs. 12,00,000 in a month, with returns of Rs. 2,00,000. Intra-State supplies (net) are Rs. 6,00,000 and inter-State Rs. 4,00,000.

Step 1: Net value = Rs. 12,00,000 minus Rs. 2,00,000 = Rs. 10,00,000.

Step 2: Intra-State: CGST 0.25% Rs. 1,500 + SGST 0.25% Rs. 1,500. Inter-State: IGST 0.5% of Rs. 4,00,000 = Rs. 2,000.

Result: Total TCS = Rs. 5,000, reported in GSTR-8 by the 10th of the next month.

Chapter summary

• Three ledgers: cash (any liability), credit (output tax only) and liability register; challans are valid for 15 days; PMT-09 moves cash between heads and to distinct persons.

• IGST credit is used first; CGST and SGST credits cannot cross; from February 2026 the IGST balance can be split between CGST and SGST in any proportion.

• Interest at 18% is on net cash paid late; cash deposited before the due date is excluded; interest on wrong ITC applies only from utilisation.

• DRC-03 for voluntary payment; DRC-03A to link it to a demand.

• TDS at 2% on Government contracts above Rs. 2.5 lakh (GSTR-7); TCS at 0.5% by e-commerce operators from 10 July 2024 (GSTR-8).

© Vipin Nair. This guide is for reading online only. Copying, downloading, printing and redistribution are not permitted. For study and general reference; not legal, tax or investment advice.