Rule 62: CMP-08 by the 18th, GSTR-4 by 30 June

Rule 62 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

A composition dealer files five things a year: four quarterly statements and one annual return. The distinction between those two words is written into the rule's own heading, and it decides which document carries the payment and which carries the detail.

Rule 62(1) requires a statement of self-assessed tax in FORM GST CMP-08 for every quarter, by the 18th of the month succeeding it, and a return in FORM GSTR-4 for every financial year, by 30 April following — moved to 30 June for FY 2024-25 onwards by Notification No. 12/2024-CT dated 10.07.2024. Rule 62(2) requires the liability to be discharged by debiting the electronic cash ledger. Rule 62(4) carries over the old regular-scheme returns on entry, with an express bar on pre-entry credit.

Statement and return are different documents

The rule's heading was substituted by Notification No. 20/2019-CT dated 23.04.2019, from "Form and manner of submission of quarterly return by the composition supplier" to "Form and manner of submission of statement and return".

Before that change, GSTR-4 was quarterly. The 2019 substitution split the obligation: a quarterly payment statement in CMP-08, and an annual return in GSTR-4.

And the contents differ sharply. Rule 62(3) requires the return to include "invoice wise inter-State and intra-State inward supplies received from registered and un-registered persons" and "consolidated details of outward supplies made".

Read that asymmetry. Outward supplies go in consolidated — the composition dealer charges no tax and issues bills of supply, so there is nothing invoice-level for the recipient to match. Inward supplies go in invoice-wise, because that is where the department's cross-check lives: a dealer whose purchases greatly exceed the turnover declared has a problem visible on the face of the return.

The 30 June proviso, and the one place it did not reach

Proviso to Rule 62(1), inserted by Notification No. 12/2024-CT dated 10.07.2024: "the return in FORM GSTR-4 for a financial year from FY 2024-25 onwards shall be required to be furnished by the registered person till the thirtieth day of June following the end of such financial year."

So the annual return calendar now runs: FY 2023-24 and earlier — 30 April; FY 2024-25 onwards — 30 June.

But Rule 62(5), the withdrawal-year sub-rule, still reads 30 April. It requires a person withdrawing from the scheme to furnish CMP-08 for the period they paid composition tax by the 18th of the month succeeding the quarter in which the date of withdrawal falls, and GSTR-4 for that period "till the thirtieth day of April following the end of the financial year during which such withdrawal falls". The 2024 proviso was attached to sub-rule (1) and sub-rule (5) was not amended alongside it. File the withdrawal-year GSTR-4 on the earlier date unless a clarification issues.

Rule 62(2): cash ledger only

"Every registered person furnishing the statement under sub-rule (1) shall discharge his liability towards tax or interest payable under the Act or the provisions of this Chapter by debiting the electronic cash ledger."

This follows inevitably from s.10(4), which denies any credit of input tax — there is no credit ledger balance to debit.

The sub-rule was itself narrowed by Notification No. 20/2019-CT, from "tax, interest, penalty, fees or any other amount" to "tax or interest", matching the statement's function.

And the payment sits on CMP-08, not GSTR-4. The annual return reports; the quarterly statement pays. A dealer who files GSTR-4 diligently but skips CMP-08 has under-paid all year, with interest running under s.50.

Rule 62(4): the year you come in

"A registered person who has opted to pay tax under section 10 from the beginning of a financial year shall, where required, furnish the details of outward and inward supplies and return under rules 59, 60 and 61 relating to the period during which the person was liable to furnish such details and returns till the due date of furnishing the return for the month of September of the succeeding financial year or furnishing of annual return of the preceding financial year, whichever is earlier."

Rules 59, 60 and 61 are GSTR-1, the inward-supply details and GSTR-3B. The sub-rule keeps the tail of the regular-scheme compliance alive after entry, so pending returns for the earlier period still have to be filed.

The ICAI Handbook records the outer date as 30 November of the succeeding financial year, reflecting the general extension of the September deadline for amendments and credit.

And the Explanation to Rule 62(4) is the sharp part: "the person shall not be eligible to avail input tax credit on receipt of invoices or debit notes from the supplier for the period prior to his opting for the composition scheme."

So filing the old return does not reopen credit. Invoices for the pre-entry period that arrive after entry are dead for credit purposes — which, together with the ITC-03 reversal on entry, is why the switch should be timed around a low-stock, low-pipeline moment. ITC-03 in, ITC-01 out →

GSTR-9A, and why almost nobody files it

Section 44 requires an annual return, and GSTR-9A is the composition form. It has been made optional or exempt every single year since 2017-18 for taxpayers below ₹2 crore of aggregate turnover:

• FY 2017-18 to 2019-20 — optional, Notification No. 47/2019-CT as amended by 77/2020-CT, deemed furnished if not filed;
• FY 2020-21 to 2023-24 — exempt, Notification Nos. 31/2021, 10/2022, 32/2023 and 14/2024-CT;
• FY 2024-25 onwards — exempt, Notification No. 15/2025-CT dated 17.09.2025, for aggregate turnover up to ₹2 crore in the year.

And ₹2 crore is above every composition threshold. The goods scheme caps at ₹1.5 crore and the service scheme at ₹50 lakh, so a compliant composition dealer is always within the exemption. GSTR-9A is effectively dead for composition taxpayers — but the exemption is turnover-based, so it is the aggregate turnover figure, not the scheme, that carries it.

The three-year bar now closes both doors

Section 39(11), inserted by the Finance Act, 2023, bars furnishing a return for a tax period after three years from its due date, and s.44(2) does the same for the annual return. Both carry a proviso allowing the Government to extend by notification, and both were brought into force for return periods from November 2025.

So a composition dealer's exposure has changed shape. A GSTR-4 that used to sit unfiled indefinitely, accruing late fee under s.47(1) at ₹100 per day per Act subject to a ₹5,000 cap — rationalised for GSTR-4 by Notification No. 73/2017-CT dated 29.12.2017 as amended — now becomes permanently unfilable three years after its due date.

Which converts a fee problem into a records problem. With no return on the portal for that year, the turnover declared is whatever the department reconstructs, and the taxpayer has lost the statutory means of stating its own figure.

Key takeaways

• CMP-08 is a statement due by the 18th; GSTR-4 is a return due 30 April, and 30 June from FY 2024-25.
• Rule 62(5), for the withdrawal year, still says 30 April — the 2024 proviso amended sub-rule (1) only.
• Liability is discharged only by debiting the cash ledger, because s.10(4) denies credit.
• GSTR-4 carries invoice-wise inward supplies and consolidated outward supplies.
• The Explanation to Rule 62(4) bars credit on pre-entry invoices even where the old return is still to be filed.
• GSTR-9A is exempt for turnover up to ₹2 crore, most recently by Notification No. 15/2025-CT, so composition dealers are always covered.
• Section 39(11) and s.44(2) now make returns unfilable three years after the due date.

Read next

• Rule 6: Lapse, Withdrawal and the CMP-04 to CMP-07 Chain
• Entering and Exiting: ITC-03 In, ITC-01 Out
• Rule 7 Rate Table, Column by Column
• Reverse Charge and the Composition Dealer

Disclaimer: Positions stated as on 5 September 2026, based on Rule 62 of the CGST Rules, 2017 and sections 39, 44 and 47 of the CGST Act, 2017 as recorded in the ICAI Bare Law (12th edition, amended to 31 March 2026), Notification No. 12/2024-CT dated 10.07.2024 and Notification No. 15/2025-CT dated 17.09.2025, and the ICAI Handbook on Composition Scheme under GST (February 2026, 3rd edition).