The quarterly statements do not close the year
A composition taxpayer should reconcile each filed CMP-08 with its underlying records, then complete the applicable annual or part-year GSTR-4. Table 5 shows details declared in filed CMP-08 statements. Table 6 shows the annual inward and outward supplies attracting tax and needs its own source data. Use the tax payment and ledger records to confirm what was actually paid. A mismatch can be a real shortfall, a classification error or a missing annual entry.
Read the applicable text: CBIC CGST Rules compilation, underlying Rule 62 subject to later amendments Gazette notification 12/2024–Central Tax, Rule 62(1) proviso Gazette of India text, notification 05/2026–Central Tax, paragraphs 1 and 14 GSTN GSTR-4 annual offline utility guidance GSTN annual GSTR-4 and Negative Liability Statement guidance.
Use the correct rule and calendar
Notification 12/2024–Central Tax inserted the Rule 62(1) proviso making the annual GSTR-4 due by 30 June following the financial year, from FY 2024–25 onward. Notification 05/2026–Central Tax separately replaces April with June in Rule 62(5), effective 1 November 2026, for the return covering the composition period when the taxpayer withdraws its section 10 option or the proper officer withdraws it. For a year ending 31 March 2027 the June date is 30 June 2027 under these rules, subject to any subsequent relief. The October 2026 amendment does not by itself reopen a past due date. CMP-08 is ordinarily due by the 18th of the month after the quarter; on a Rule 62(5) withdrawal, the final applicable CMP-08 covers the composition period in the withdrawal quarter and is due by the 18th day of the month after that quarter, where required. Check any class-specific extension separately. This article covers section 10 composition.
Build a supply-and-payment bridge
Work GSTIN by GSTIN. Fix the exact composition dates first, especially for a mid-year move to regular tax. Reconcile outward supplies and purchases attracting reverse charge to the books, identify any additional tax head and separate composition-period amounts from regular returns. Use Table 4 categories as applicable. The GSTN offline utility identifies Table 6 rows 12–16 for rate-wise outward supply entry. Its Compute function carries applicable reverse-charge details from Tables 4B, 4C and 4D into Table 6. Table 5 is auto-drafted from filed CMP-08 statements; confirm actual payment and allocation separately in the ledgers. Verify both imported and manually entered figures against the live preview before filing.
Explain each difference before paying or claiming a balance
Bridge liability and amounts paid for each applicable tax head, and then review interest or late fee separately. GSTN has documented a historical problem where omission of Table 6 entries produced an apparent excess in the Negative Liability Statement. An apparent excess does not establish a refund or usable credit. Check the annual preview before filing. If the return was already filed, do not assume you can revise it or use the apparent balance; identify the applicable portal support or jurisdictional correction route.
Close the file with acknowledgements
Keep quarterly filed statements, annual preview, final return, filing acknowledgement and the before-and-after ledger evidence. For a change in scheme keep effective-date proof and split records on either side. A return that calculates correctly can still be wrong if it includes transactions from the wrong period, GSTIN or tax category.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: New-year calendar
For FY 2026–27 ending 31 March 2027, the 30 June 2027 annual deadline is 91 calendar days after year-end. Put the quarterly statement dates on separate calendar lines.
Illustrative example 2: Quarterly figures match
Four CMP-08 tax amounts are ₹12,000, ₹9,000, ₹11,000 and ₹14,000, giving ₹46,000. If annual liability independently totals ₹46,000 in matching heads, the aggregate difference is nil.
Illustrative example 3: Outward liability was understated
Annual outward tax is ₹34,500 against ₹32,000 paid under the corresponding heads and reverse charge matches. The unexplained outward difference is ₹2,500; review the period and any interest separately.
Illustrative example 4: Reverse charge gap
Correct reverse charge is ₹9,800 and statements show ₹7,200 on that category. Investigate a ₹2,600 shortfall rather than moving the same amount to outward supplies.
Illustrative example 5: Blank outward supply data
An annual preview shows ₹4,000 from reverse charge but omits supported outward liability of ₹26,000. If quarterly payments total ₹30,000 in matching heads, the draft reconciliation shows an apparent excess of ₹26,000. This preview difference is not itself a ledger credit. Correctly entering the outward amounts brings annual liability to ₹30,000 and removes that apparent difference.
Illustrative example 6: Split the scheme periods
Book sales are ₹52 lakh; ₹18 lakh fall in the verified composition interval and ₹34 lakh in the later regular period. Build GSTR-4 outward details from the ₹18 lakh population and reconcile the other ₹34 lakh to the regular-period working. The turnover split does not by itself calculate tax.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Confirm GSTIN and the annual period | Registration and filed-return list |
| 2 | Lock composition start and end dates | Portal status and effective-date evidence |
| 3 | Retrieve each filed quarterly statement | CMP-08 acknowledgements and payment detail |
| 4 | Extract books for the relevant interval | Dated sales and purchase registers |
| 5 | Check outward categorisation | Rate and turnover working |
| 6 | Review reverse charge separately | Supplier and invoice-level RCM schedule |
| 7 | Compare the portal summary to payments | Table 5 and head-wise quarterly ledger |
| 8 | Complete and inspect annual liability | Table 6 and the return preview |
| 9 | Investigate differences before settlement | Variance list, correction notes and ledger checks |
| 10 | Preserve filing evidence | Final GSTR-4, acknowledgement and payment references |
Sixteen practitioner FAQs
1. Is CMP-08 the annual return?
No. CMP-08 is the quarterly statement; GSTR-4 closes the applicable annual or part-year period.
2. What was the first year covered by the June proviso?
FY 2024–25 under Notification 12/2024–Central Tax.
3. What changed in November 2026?
From 1 November 2026, Notification 05/2026 replaced April with June in Rule 62(5), which addresses withdrawal of the section 10 composition option.
4. Does that amendment reopen older overdue returns?
Do not infer that from the substitution. Check separately for notified relief for the relevant period and class.
5. Is the GSTR-4 date the same as the CMP-08 date?
No. Keep annual and quarterly compliance deadlines separate.
6. Does Table 5 come from the trial balance?
GSTN describes it as auto-drafted from filed CMP-08 statements. Reconcile it to the trial balance and payment records.
7. Should Table 6 be left blank if payments match the books?
No. Enter the required annual details even when there is no final difference.
8. Which rows are for outward supplies in the GSTN offline guidance?
The guidance identifies rows 12–16 of Table 6 for tax-rate-wise outward supply details.
9. Is an annual preview proof of filing?
No. Preserve the acknowledgement and filed return.
10. Should GSTINs be combined if they share a PAN?
Prepare and reconcile the form for its GSTIN; use PAN-level data separately where relevant to legal eligibility.
11. What if the scheme changed during the financial year?
Use effective dates to split the composition and regular periods and verify each filing obligation.
12. Should reverse charge and outward liability be reconciled separately?
Yes. Confirm source transactions, amounts paid and tax heads.
13. Does the Negative Liability Statement always show an amount recoverable?
No. Check the source of the entry; omitted annual liability can create an apparent excess.
14. Can I net two different tax heads in the working?
Show each head separately and apply the applicable portal and statutory rules before any set-off.
15. Is interest included in the book-to-return turnover comparison?
No. Compute and document interest separately from the supply base and principal tax.
16. What if Table 5 differs from the quarterly payment ledger?
Check statement status, period, GSTIN, tax head and posting dates before choosing a correction route.
Official sources
CBIC CGST Rules compilation, underlying Rule 62 subject to later amendments Gazette notification 12/2024–Central Tax, Rule 62(1) proviso Gazette of India text, notification 05/2026–Central Tax, paragraphs 1 and 14 GSTN GSTR-4 annual offline utility guidance GSTN annual GSTR-4 and Negative Liability Statement guidance