Due dates for May 2023

Due dates for May 2023

May packs more statutory deadlines than any other month in India's compliance calendar. GSTR-1, GSTR-3B and PMT-06 for April, TDS deposit and Q4 return filing, Form 27EQ for TCS, EPF and ESIC contributions, LLP annual return and the Statement of Financial Transactions all converge between 7 May and 31 May. Miss even one and you trigger automatic late fees, compounding interest and — for TDS defaults — a notice under Section 201 that follows you through the entire assessment cycle. This calendar gives you every date, every form name, the exact penalty formula and a worked Rs. example so you can plan the month rather than just survive it.

Why May Is the Heaviest Compliance Month in India

Three forces collide in May and create a compliance pressure that no other month matches.

Year-end TDS filings fall due. The Q4 TDS returns — Forms 24Q, 26Q and 27Q — covering January to March must be filed by 31 May. These returns must be accurate before TRACES generates Form 16 and Form 16A. A correction statement after the original filing delays certificate issuance and creates short-deduction demands in the processing cycle.

Month-end GST and payroll obligations run on schedule. April GST liabilities are due for payment and reporting in May regardless of how stretched the team is with year-end close. April EPF and ESIC contributions must also be deposited by 15 May. Neither deadline moves simply because the team is also closing books.

MCA's annual rhythm begins. LLPs must file Form 11 by 30 May, and companies are often still executing April board resolutions — allotments, director changes, charge creations — whose 30-day filing window expires in May.

GSTN, TRACES and MCA V3 all impose automatic penalties without any manual intervention. A single-day slip generates a fee that appears in the next filing's demand. The only way through May is a structured four-week sprint, not a normal working month.

GST Due Dates in May

10 May — GSTR-7 and GSTR-8

GSTR-7 is filed by government entities and specified persons who deduct TDS on payments to GST-registered suppliers under Section 51 of the CGST Act 2017. This covers TDS deducted on April payments. Late fee: Rs. 100/day each under the CGST and SGST Acts (Rs. 200/day combined), capped at Rs. 5,000 per Act.

GSTR-8 is filed by e-commerce operators (under Section 52 CGST) who collect TCS from sellers on their platforms. The TCS collected in April must be reported here. The same Rs. 200/day combined late fee applies.

11 May — GSTR-1 for Monthly Filers

This is the outward supply statement for April, mandatory for taxpayers with aggregate annual turnover above Rs. 5 crore or those who have opted out of the QRMP scheme. A delayed or inaccurate GSTR-1 directly blocks the recipient's ITC in GSTR-2B for the following month. Late fee: Rs. 200/day (Rs. 100 CGST + Rs. 100 SGST), capped at Rs. 10,000 per return.

Before hitting Submit, reconcile the GSTR-1 figures against your books — invoice-wise. Post-filing corrections require an amendment in the next month's GSTR-1, which defers the recipient's ITC and can trigger vendor escalations.

13 May — IFF and GSTR-6

Invoice Furnishing Facility (IFF) is available to QRMP scheme taxpayers to upload April B2B invoices so recipients can see them in GSTR-2B without waiting for the quarterly GSTR-1. IFF is optional but practically essential if you are supplying to GST-registered buyers — they may hold payment pending ITC confirmation.

GSTR-6, filed by Input Service Distributors, distributes ITC among branches for April. If your entity holds an ISD registration, this is a hard deadline with no grace period.

20 May — GSTR-3B for Monthly Filers

This is the highest-stakes GST deadline of the month. GSTR-3B is the summary return where you declare net liability and make payment. Interest under Section 50 of the CGST Act accrues at 18% per annum on any unpaid tax starting the day after the due date — no notice required, no manual assessment.

Late fee rates for GSTR-3B depend on aggregate annual turnover:

• Above Rs. 5 crore: Rs. 50/day (Rs. 25 CGST + Rs. 25 SGST)
• Above Rs. 1.5 crore, up to Rs. 5 crore: Rs. 25/day (Rs. 12.50 CGST + Rs. 12.50 SGST)
• Up to Rs. 1.5 crore: Rs. 20/day (Rs. 10 CGST + Rs. 10 SGST)
• Nil-liability return: Rs. 20/day regardless of turnover

25 May — PMT-06 for QRMP Filers (April Tax Payment)

QRMP taxpayers file GSTR-3B quarterly, not monthly. Their Q1 (April–June) GSTR-3B will be due in July. However, they must make a monthly tax payment for April via Challan PMT-06 by 25 May. Two options exist: the fixed-sum method (deposit 35% of the net cash liability paid in the last quarter's GSTR-3B) or the self-assessment method (calculate actual April liability and pay that amount). Underpayment at this stage attracts interest under Section 50 when the quarterly GSTR-3B is eventually filed.

Note: The 22/24 May GSTR-3B dates sometimes cited for QRMP filers in older compliance calendars refer to the quarterly GSTR-3B for Q4 (January–March), which falls due in April, not May. In the May calendar, the relevant QRMP obligation is PMT-06 on 25 May.

28 May — GSTR-11 by UIN Holders

UIN holders — embassies, consulates, international organisations and UN bodies — file GSTR-11 for April to claim refunds on their inward supplies. This is a small universe of filers but a non-negotiable deadline for those entities.

TDS and TCS Deadlines in May

7 May — Deposit of TDS and TCS for April

Every deductor must deposit April TDS and every collector must deposit April TCS by 7 May using Challan 281 via the TIN 2.0 (OLTAS) interface. April is the first TDS month of FY 2026-27, which means fresh employee declarations (Form 12BB), revised Section 192 projections for salary TDS and updated vendor certificates under Sections 197/206AB all take effect.

Interest for late deposit after deduction: 1.5% per month or part of a month under Section 201(1A). A deposit on 8 May — one day late — counts as a full month of interest.

Interest where TDS was not deducted at all: 1% per month for the period from when deduction was due to when it is actually made.

15 May — Q4 TCS Return (Form 27EQ)

The TCS return for January–March is due 15 May. This covers TCS collected under Section 206C on scrap, timber, tendu leaves, minerals, alcoholic liquor and under Section 206CQ on foreign remittances exceeding Rs. 7 lakh (LRS), overseas tour packages and sale of goods exceeding Rs. 50 lakh per buyer.

Late fee under Section 234E: Rs. 200 per day, subject to a cap equal to the TCS amount in the return. After Form 27EQ is accepted on TRACES, Form 27D (TCS certificate) must be issued to buyers within 15 days — so by 30 May.

31 May — Q4 TDS Returns (Forms 24Q, 26Q, 27Q)

The Q4 filing is the most consequential deadline of the month:

• Form 24Q: Salary TDS for all employees for January–March, including Annexure II (complete year reconciliation)
• Form 26Q: Non-salary domestic TDS — contractors (Section 194C), rent (Section 194I), professional fees (Section 194J), commission (Section 194H), interest (Section 194A) and others
• Form 27Q: TDS on payments to non-residents under Section 195, 196A, 196B and others

Late fee under Section 234E: Rs. 200 per day per Act, capped at the TDS amount in the return. For a company with Rs. 4 lakh in Q4 salary TDS, a 20-day delay costs Rs. 4,000 (Rs. 200 × 20, which is below the Rs. 4,00,000 cap).

> A critical misconception to correct: Form 16 (salary TDS certificate) is not due on 31 May. Under Rule 31(1)(a) of the Income Tax Rules 1962, Form 16 must be issued on or before 15 June of the financial year immediately following the year in which income was paid. The 31 May deadline is for filing Form 24Q — the prerequisite for generating Form 16 Part A from TRACES. File Form 24Q accurately and on time; that is the only lever in your control to ensure employees receive Form 16 before 15 June. Similarly, Form 16A (non-salary TDS certificate) for Q4 is due 15 June — 15 days after the 31 May filing deadline.

PF, ESIC and Payroll Deadlines

15 May — EPF and ESIC Contributions for April

Both the Employee Provident Fund (EPF) and Employee State Insurance Corporation (ESIC) contributions for April must be deposited by 15 May.

EPF: Upload the Electronic Challan cum Return (ECR) on the EPFO Unified Portal. The challan covers the employer's 12% and employee's 12% PF contributions, plus EDLI (0.5%) and administrative charges (0.50% / 1.1% depending on the category). Late payment attracts damages under Section 14B of the EPF Act — up to 25% per annum for delays beyond six months — and penal interest from day one.

ESIC: Contributions at 3.25% (employer) and 0.75% (employee) on wages up to Rs. 21,000 per month are payable via the ESIC portal. Late payment attracts simple interest at 12% per annum and damages up to 25% of contributions where delay is deliberate or prolonged.

Lock the April payroll register and finalise headcount by 10 May at the latest. The ECR must show accurate UAN-wise data; any mismatch between ECR headcount and payroll records triggers EPFO reconciliation notices that are time-consuming to respond to.

Professional Tax — State-Specific Dates

Professional tax is levied by state governments, and due dates vary:

• Maharashtra: Monthly PTRC payment and return for April due 31 May (last day of the month for monthly registrants)
• Karnataka: Payment due by the 20th of the following month, so 20 May for April
• West Bengal: Payment by 21 May for April
• Tamil Nadu: Half-yearly cycle — check your PT registration certificate for exact due dates

Multi-state employers should maintain a separate state-wise PT calendar; it is easy to miss a state deadline when tracking GST and TDS takes up bandwidth.

Year-End Payroll Tasks

May is also when HR and payroll teams close FY 2025-26 payroll:

• Process full-and-final settlements for employees who separated before 31 March, including leave encashment, gratuity (Section 4, Payment of Gratuity Act 1972) and reimbursement claims
• Issue revised pay slips for any arrear adjustments processed in March
• Collect Form 12BB declarations from all employees for FY 2026-27 to update monthly TDS from May onwards

MCA and Company Law Filings

30 May — LLP Form 11 (Annual Return)

Every LLP registered under the LLP Act 2008 must file Form 11 (Annual Return) within 60 days of the close of the financial year. Since the financial year ends 31 March, the deadline is 30 May. Form 11 is filed on the MCA V3 portal and must include:

1. Details of designated partners and partners as on 31 March
2. Partner contribution details (monetary and non-monetary)
3. Summary of business activities and nature of business
4. Digital signature of at least one designated partner

Late filing attracts an additional fee of Rs. 100 per day from the first day of default, with no statutory cap. A filing that is 90 days late accumulates Rs. 9,000 in additional fees before MCA even processes the form. Keep your designated partners' DSCs current on MCA V3 — an expired or unregistered DSC on the day of filing will force you to seek an extension or absorb additional days' fees while getting the DSC sorted.

31 May — Statement of Financial Transactions (Form 61A)

Specified reporting entities — scheduled commercial banks, NBFCs, mutual funds, registrars of documents, companies issuing buyback rights, and others listed under Rule 114E of the IT Rules — must file Form 61A for FY 2025-26 via the Income Tax portal by 31 May. Failure to file attracts Rs. 500 per day under Section 271FA, escalating to Rs. 1,000 per day after the date specified in a deficiency notice.

Event-Based MCA Filings Within 30 Days

If any corporate event occurred in April — director appointment or resignation (Form DIR-12), change of registered office (Form INC-22), share allotment (Form PAS-3) or a significant board resolution requiring Form MGT-14 — the 30-day filing window falls in May. Review all April board resolutions in the first week of May and file all pending event-based forms before the 30-day window closes.

Worked Example: The Cost of Three Missed May Deadlines

Company profile: Precision Parts Pvt Ltd, aggregate annual turnover Rs. 8 crore, 45 employees, 2 directors, monthly GST filer.

GSTR-3B — 16 days late

• April liability: Rs. 1,80,000 (Rs. 90,000 CGST + Rs. 90,000 SGST)
• Late fee (turnover > Rs. 5 crore, Rs. 50/day): Rs. 50 × 16 = Rs. 800 (Rs. 400 CGST + Rs. 400 SGST)
• Interest u/s 50 CGST (18% p.a.): Rs. 1,80,000 × 18% × 16 ÷ 365 = Rs. 1,421
• Sub-total: Rs. 2,221

TDS deposit — 18 days late

• April TDS on contractor payments (Section 194C): Rs. 68,000
• Interest u/s 201(1A) at 1.5% per month, part month = full month (1 month applies): Rs. 68,000 × 1.5% = Rs. 1,020
• Sub-total: Rs. 1,020

Form 24Q Q4 — 20 days late

• Penalty u/s 234E: Rs. 200/day × 20 = Rs. 4,000
• Q4 salary TDS: Rs. 3,20,000 → cap not breached
• Sub-total: Rs. 4,000

Total statutory cost from three preventable delays: Rs. 7,241

But the penalty arithmetic understates the real damage. Because Form 24Q was filed 20 days late, TRACES cannot generate Form 16 Part A until the return is processed — typically 3–5 working days after acceptance. That means 45 employees wait until late June or early July for Form 16, disrupting home loan processing and income tax return filing for each of them. Those are 45 follow-up emails, 45 HR complaints and one auditor observation in the statutory audit report.

Year-End Book Closure Tasks Running Parallel to May Filings

By 1 May, many businesses are still finalising March-end provisions, depreciation schedules, FOREX revaluations on trade payables and inter-company reconciliations. These cannot be deferred to June; the statutory audit clock is running. The solution is a structured four-week sprint:

Week 1 (1–7 May): Lock the 31 March trial balance. Finalise all provisions — gratuity actuarial valuations, doubtful debt provisions and bonus payable. Revalue FOREX items at closing rate. Deposit April TDS by 7 May.

Week 2 (8–15 May): File GSTR-1 (11 May), IFF and GSTR-6 (13 May). Reconcile GSTR-2B against the purchase register — flag mismatches before filing GSTR-3B. File Form 27EQ (15 May). Submit EPF and ESIC ECR by 15 May. Begin TDS data extraction and validation on TRACES for the Q4 return.

Week 3 (16–25 May): File GSTR-3B by 20 May. Process PMT-06 for QRMP filers by 25 May. Prepare Form 11 for LLPs — collect partner details, confirm contributions and verify DSC validity.

Week 4 (26–31 May): File LLP Form 11 before 30 May (not on 30 May — portal congestion on the last day is real). File Forms 24Q, 26Q and 27Q by 31 May after a final PAN-wise reconciliation. Verify Form 61A SFT data and file by 31 May. On 1 June, initiate Form 16 Part A generation on TRACES.

Pitfalls to Avoid in May

1. Confusing the Form 16 deadline with the Form 24Q deadline Form 16 is due 15 June under Rule 31. The 31 May deadline is for Form 24Q. File 24Q on time and accurately; that is the only way to have Form 16 ready for employees well before the statutory date. Issuing Form 16 before Form 24Q is accepted on TRACES is technically improper — Part A must be downloaded from TRACES after the return is processed.

2. Filing GSTR-1 without a pre-upload reconciliation Generating GSTR-1 directly from billing software without cross-checking against your books is the single most common source of amendment returns. Differences in credit notes, advance receipts and high-sea sales are frequently missed. Build a 30-minute reconciliation step before every GSTR-1 upload.

3. Expired or unregistered DSC for LLP Form 11 MCA V3 requires DSCs to be registered in the portal's DSC management module before they can be used for signing. A newly generated DSC, or one renewed after the previous registration expired, must be re-registered before the deadline. Check DSC validity and portal registration status by 15 May — do not discover the problem on 29 May.

4. Using the wrong PMT-06 method for QRMP If you choose the fixed-sum method (35% of last quarter's net cash liability) but your April liability is significantly higher, you will face interest on the shortfall when the Q1 GSTR-3B is filed. If April has large input tax credits that reduce liability substantially, the self-assessment method saves cash. Evaluate the method in the first week of May, not the last.

5. Processing TDS challans through legacy NSDL pathways after TIN 2.0 migration TIN 2.0 is now the authoritative system for TDS/TCS challans. Challans created through old interfaces may not reflect correctly in the deductee's AIS or Form 26AS. After every challan payment, verify the CIN (Challan Identification Number) on the TIN 2.0 dashboard within 24 hours of the payment date.

6. Omitting April joiners and leavers from the EPF ECR Employees who joined after 1 April or left before 30 April must still appear in the ECR with wages proportionate to their working days. Omission triggers EPFO scrutiny and can result in damages under Section 14B being levied on the entire establishment — not just the omitted employees.

Working Capital Planning for May's Back-to-Back Outflows

May compresses statutory outflows into a three-week window. A business with Rs. 3 crore in monthly turnover and standard statutory obligations will typically face:

Total statutory cash outflow in three weeks: Rs. 6–11 lakh, before any advance tax consideration.

Three practical steps to manage this:

1. Open a statutory reserves sub-account. On the first working day of each month, sweep the estimated GST, TDS and payroll liability into a separate current account. This money is not available for working capital. The discipline removes the anxiety of 20 May because the funds are already parked.

1. Accelerate April receivables. Offer a 0.25–0.5% early payment discount to key customers for settlement before 15 May. The cost of the discount is almost always less than the cost of statutory interest — 0.5% on a Rs. 20 lakh invoice is Rs. 1,000, against 18% GST interest per annum on unpaid tax.

1. Pre-draw on overdraft before 7 May. If your current account is linked to a pre-approved overdraft, draw on it before the first major payment date. Bank overdraft interest for five days to bridge a liquidity gap is materially cheaper than 1.5% per month Section 201(1A) interest — the latter also creates a notice trail; the former does not.

Interest under Section 201(1A), Section 50 of the CGST Act and EPFO's Section 14B damage provisions compound quickly and without any grace period. The cost of statutory default is almost always higher than the cost of arranging liquidity in advance.

Key Takeaways

• 7 May: TDS and TCS deposit for April — the month's first hard deadline. One day's delay costs 1.5% per month under Section 201(1A); the interest calculation treats any part of a month as a full month.
• 20 May: GSTR-3B for monthly filers (annual turnover > Rs. 5 crore); interest at 18% per annum under Section 50 starts the next day automatically.
• 25 May: PMT-06 challan for QRMP filers — this is the May GST obligation for QRMP taxpayers, not a GSTR-3B. The quarterly GSTR-3B for Q1 (April–June) is due in July.
• 31 May: Q4 TDS returns (Forms 24Q, 26Q, 27Q) and Form 61A (SFT) — file these accurately, not just on time; TRACES processes Form 24Q before generating Form 16 Part A.
• Form 16 is due 15 June, not 31 May — rushing Form 24Q without reconciliation just to meet 31 May creates a bigger problem in June when TRACES returns errors.
• LLP Form 11 is due 30 May; the Rs. 100/day additional fee is uncapped — a 90-day delay already costs Rs. 9,000 before MCA processes the return, and DSC issues add more days.
• Build a four-week sprint with specific deliverables in each week, and park statutory liabilities in a dedicated sub-account from Day 1 of April — May's cash crunch is fully predictable and entirely avoidable with 30 days of forward planning.