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Microlesson · 5-min read

Composition Scheme - Procedural Compliances and Common Rules

# Procedural Aspects of Composition Scheme

This lesson covers the procedural and compliance side of the composition scheme — opting in, opting out, returns, payments, and continuing conditions. These rules apply to BOTH Section 10(1)/10(2) (goods/restaurants) and Section 10(2A) (services/mixed).

## A. Opting In

ActionFormTiming
Intimation to opt for composition (at start of FY)Form GST CMP-02Before commencement of FY
Intimation to opt at the time of registrationForm GST REG-01 (Part B)At registration
Statement of ITC reversal on opting in (stock-related)Form GST ITC-03Within 60 days of commencement of FY (or scheme opting)

## B. Continuing Conditions (Rule 5)

1. Must NOT be a CTP or NRTP.

2. Goods held in stock should NOT have been purchased in inter-State trade / from unregistered persons (where applicable).

3. Must pay tax under RCM on inward supplies at NORMAL rates (not composition rate).

4. Must mention 'Composition taxable person' on every notice / signboard at place of business.

5. Must mention 'Composition taxable person, not eligible to collect tax on supplies' at the top of the Bill of Supply.

6. Cannot issue a Tax Invoice; must issue a Bill of Supply.

## C. Opting Out / Withdrawal

  • Voluntary withdrawal: File Form GST CMP-04 within 7 days of withdrawal.
  • Automatic lapse: If T/O exceeds threshold mid-year, the option lapses from the date of crossing.
  • Stock statement on the date of opting out must be furnished (for ITC restoration).

## D. Returns and Payment

ComplianceFormFrequencyDue Date
Tax PaymentForm CMP-08Quarterly18th of the month following the quarter
Annual ReturnForm GSTR-4Annually30th June of the succeeding FY

### Quarterly Payment Due Dates

QuarterDue Date
Apr - Jun18th July
Jul - Sep18th October
Oct - Dec18th January
Jan - Mar18th April

## E. Key Restrictions Common to Both Schemes

  • No ITC available on inward supplies.
  • Cannot collect GST from recipient.
  • Cannot make inter-State OUTWARD supplies of goods (services to a limited extent under 10(2A)).
  • Cannot supply through ECO required to collect TCS.
  • Cannot supply non-taxable goods.

Worked example

### Example 1

Example 1 - Mid-year crossing of threshold:

Mr. A (composition dealer, normal State) had PFY T/O Rs. 1.3 crore. During FY 2025-26, he crosses Rs. 1.5 crore on 15th November 2025. From which date does the composition scheme cease?

Answer: The option lapses from 15th November 2025 (date of crossing). From that date, he must pay tax at normal rates and switch to regular registration. He must file CMP-04 within 7 days and furnish a stock statement to claim ITC on stock.

### Example 2

Example 2 - Computing Q2 payment due date:

Ms. B opted under 10(2A). Her Q2 (Jul-Sep 2025) turnover is Rs. 7,00,000. Compute tax and due date.

Answer: Tax = 6% × Rs. 7,00,000 = Rs. 42,000 (CGST Rs. 21,000 + SGST Rs. 21,000). Due date in Form CMP-08: 18th October 2025.

### Example 3

Example 3 - Invoice type:

A composition dealer makes a sale worth Rs. 10,000. What document does he issue?

Answer: A Bill of Supply (not Tax Invoice), with the declaration at the top: 'Composition taxable person, not eligible to collect tax on supplies'.

⚠️ Common exam mistakes

  • Filing GSTR-1/GSTR-3B instead of CMP-08 and GSTR-4 - composition dealers do NOT file regular monthly returns.
  • Issuing Tax Invoice instead of Bill of Supply.
  • Forgetting to file CMP-04 within 7 days of withdrawal.
  • Paying RCM at composition rate - RCM is always at NORMAL applicable rate, even for composition dealers.
  • Missing the 60-day window for filing ITC-03 (reversal of ITC on stock when opting in).
  • Forgetting to mention 'Composition taxable person' on signboards and bills of supply - this is a statutory requirement.
Reference: Rules 3, 4, 5, 6, 7 of CGST Rules — CGST Rules, 2017
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