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Microlesson · 5-min read

Interest on Delayed Payment of Tax [Section 50]

# Interest on Delayed Payment of Tax — Section 50, CGST Act

Section 50 deals with interest payable for two distinct situations:

```

Section 50 — Interest

┌───────────────┴───────────────┐

↓ ↓

CASE 1 CASE 2

Delay in payment of tax Utilisation of wrongly

in full or in part availed ITC

```

Both attract interest @ 18% per annum.

## CASE 1 — Delay in Payment of Tax (Full or Part)

### Period

  • From: Day next to the due date of payment
  • To: Date of actual payment of tax

### Rate: 18% p.a.

### Base for Interest — Net or Gross Liability?

Interest is computed on NET tax liability if BOTH of the following are satisfied:

1. The return for that tax period has been filed (even if belatedly), AND

2. No proceeding under section 73/74 has been initiated.

Else — i.e., if tax is paid through a return of another period, or proceeding u/s 73/74 has been initiated — interest is computed on GROSS tax liability (without setting off ITC).

### Important Sub-Rules

  • Net GST Liability = Tax payable after setting off ITC (Case 1).
  • If amount was already lying in the Cash Ledger before the due date, that amount is not considered for interest for the period it was lying there. Interest is charged only on the shortfall actually paid late.
  • Interest is charged till the date GSTR-3B is filed, considering reduced ITC balance available.

## CASE 2 — Wrongly Availed ITC that is Utilised

### Period

  • From: Day next to the date of utilisation of wrongly availed ITC
  • To: Date of reversal or repayment of such ITC

### Rate: 18% p.a.

### Base: On Excess ITC actually utilised

### Computation of "Excess ITC Utilised" for IGST

For the IGST head specifically:

> Excess ITC utilised = ITC (IGST) wrongly availed − ITC balance (IGST + CGST + SGST/UTGST) in credit ledger

>

> This is because IGST could have been paid using ITC of IGST/CGST/SGST/UTGST.

For CGST or SGST wrongly availed, the comparison is only against the same-head balance.

### What is the "Date of Utilisation"?

SituationDate of Utilisation
Credit ledger balance falls below wrongly availed ITC due to payment of tax through a returnEarlier of: (i) due date of such return, OR (ii) actual date of filing
Credit ledger balance falls below wrongly availed ITC otherwiseDate of debit in the Electronic Credit Ledger

### Key Principle

Mere availment of wrongly availed ITC does NOT attract interest. Interest is triggered only when the wrongly availed ITC has been utilised (i.e., the ledger has been actually drawn down such that it 'used' the wrongly availed credit).

If, after wrongly availing ₹5 L, the credit ledger balance remained above ₹5 L (e.g., ₹7 L), then no wrongly availed ITC has been utilised — no interest.

## Quick Reference Table

AspectCase 1: Delay in tax paymentCase 2: Wrongly availed ITC
Rate18% p.a.18% p.a.
BaseNet (or Gross) tax liabilityExcess ITC utilised
FromDay after due dateDay after date of utilisation
ToDate of paymentDate of reversal/payment

Worked example

### Example 1

CASE 1 — Scenario (i): Return Filed Late, No Proceedings Initiated

Tax liability for February:

  • Output liability ₹1,50,000
  • RCM liability ₹40,000
  • ITC balance ₹70,000
  • Cash ledger balance ₹20,000 lying from Feb to April

Return for Feb is filed on 17 April. Due date = 20 March.

Interest period: 21 March to 17 April = 28 days

Computation (Net liability — return filed, no proceedings):

  • Output ₹1,50,000 − ITC ₹70,000 = ₹80,000
  • + RCM ₹40,000 = ₹1,20,000
  • − Cash already lying ₹20,000 = ₹1,00,000

Interest = ₹1,00,000 × 18% × 28/365 = ₹1,381

### Example 2

CASE 1 — Scenario (ii): Liability Reported in a Later Period's Return

Same liabilities as Scenario (i). Return for Feb was filed on 20 March (timely) but the liability was omitted. It is now disclosed in the March return filed on 17 April.

Since tax is paid through return of another period, interest is on GROSS liability (no ITC set-off, no cash adjustment).

Interest period: 21 March to 17 April = 28 days

Gross liability = ₹1,50,000 + ₹40,000 = ₹1,90,000

Interest = ₹1,90,000 × 18% × 28/365 = ₹2,624

### Example 3

CASE 2 — Wrongly Availed ITC

ITC of ₹15,00,000 was availed in the January return (filed in February). Of this, ₹5,00,000 related to goods not yet received → wrongly availed.

In the March return, liability was discharged on 17 April (the earlier of due date 20 April or actual filing 17 April). Wrongly availed ITC was reversed/paid back on 20 June.

Period: 18 April → 20 June = 64 days

Wrongly utilised computation depends on balance remaining after utilisation:

ParticularsSituation 1Situation 2Situation 3
Tax Liability18,00,00013,00,0008,00,000
Credit Utilised15,00,00013,00,0008,00,000
Cash Payment3,00,000
Credit Available15,00,00015,00,00015,00,000
Credit Balance after utilisation02,00,0007,00,000

ITC Wrongly Utilised = Wrongly availed ₹5,00,000 − Closing Credit Balance

ParticularsSit 1Sit 2Sit 3
Wrongly availed ITC5,00,0005,00,0005,00,000
Less: Credit balance02,00,0007,00,000
Wrongly utilised5,00,0003,00,000NIL (balance > wrongly availed)

Interest @ 18% × 64/365:

  • Situation 1: ₹5,00,000 × 18% × 64/365 = ₹15,781
  • Situation 2: ₹3,00,000 × 18% × 64/365 = ₹9,469
  • Situation 3: NIL — no wrongly availed ITC was actually utilised

⚠️ Common exam mistakes

  • Charging interest on gross liability when both conditions for net liability (return filed + no s.73/74 proceedings) are satisfied.
  • Forgetting to reduce the cash ledger balance already lying (for the period it was lying) before computing interest under Case 1.
  • Charging interest from the due date itself — interest runs from the day NEXT to the due date.
  • Charging interest on mere availment of wrongly availed ITC — interest applies only when such ITC is actually utilised.
  • For IGST wrongly availed, comparing only against the IGST balance — the correct comparison is against the TOTAL of IGST + CGST + SGST/UTGST in the credit ledger.
  • Picking the wrong 'date of utilisation' — when tax is paid through a return, it is the EARLIER of due date or actual date of filing, NOT necessarily the actual filing date.
  • Forgetting that when liability of an earlier period is disclosed in a LATER period's return, interest will be on the GROSS liability (no ITC set-off allowed).
  • Using 360 days instead of 365 days for interest computation — GST uses 365 days.
Bare-Act text Section 50 of CGST Act, 2017 · CGST Act, 2017 · click to expand
Section 50 — Interest on delayed payment of tax: (1) Every person who is liable to pay tax in accordance with the provisions of this Act or the rules made thereunder, but fails to pay the tax or any part thereof to the Government within the period prescribed, shall for the period for which the tax or any part thereof remains unpaid, pay, on his own, interest at such rate, not exceeding eighteen per cent., as may be notified by the Government on the recommendations of the Council. Provided that the interest on tax payable in respect of supplies made during a tax period and declared in the return for the said period furnished after the due date in accordance with the provisions of section 39, except where such return is furnished after commencement of any proceedings under section 73 or section 74, shall be levied on that portion of the tax which is paid by debiting the electronic cash ledger. (3) Where the input tax credit has been wrongly availed and utilised, the registered person shall pay interest on such input tax credit wrongly availed and utilised, at such rate not exceeding twenty-four per cent. as may be notified by the Government, on the recommendations of the Council, and the interest shall be calculated, in such manner as may be prescribed.
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