Accounting & Compliance · Kolte Enterprises← Back to Ledger Logic
Corrugated carton, kraft paper packaging and box-making units — Income Tax, MSME 43B(h) discipline, GST inverted-duty refund, 194Q on kraft paper, factory licence and pollution-board returns.
Pay your micro-supplier on the 46th day instead of the 45th and the entire invoice value gets added back to your taxable profit. The disallowance under Sec 43B(h) does not reverse next year — it stays. A Rs 50 lakh kraft paper bill paid one day late costs you about Rs 12 lakh in tax even though you finally paid the supplier.
Source: Section 43B(h), Income Tax Act 1961, inserted by Finance Act 2023, effective from AY 2024-25.A corrugated-carton manufacturing unit is GST-classified at HSN 4819, output rate 18%. Its core inputs (kraft paper at HSN 4804, starch, glue, water, electricity) are taxed at the same 18%, while job-work labour is at 12%. That keeps the unit perpetually in inverted duty structure for some month-classes of orders, opening up refund claims under Section 54(3) of the CGST Act.
The single largest income-tax shift hitting MSME-classified manufacturers is Section 43B(h), inserted by Finance Act 2023. Payments to micro and small enterprises must be settled within 45 days (or 15 if there is no written agreement) or the expense is disallowed in the year of accrual itself. This hurts more than 40A(3) ever did because the disallowance is permanent.
The Income Tax Act 1961 — and the new Income Tax Act 2025 effective 1 April 2026 — keep the same pillars: pay advance tax on time, file an accurate return, and stay clean on cash. The KPIs below are the ones an audit officer pulls up first if your file lands on a scrutiny desk.
| KPI / Compliance Item | Threshold & Action | Due Date | Source |
|---|---|---|---|
| Tax audit u/s 44AB | Turnover above Rs 1 crore (Rs 10 crore if cash below 5%). Virtually every box manufacturer falls inside. | 30 Sep 2027 | Sec 44AB |
| Sec 43B(h) — MSME 45-day rule | Payments to micro and small enterprises (per Udyam registration under MSMED Act) must be made within 45 days, or 15 if there is no written agreement. Otherwise the expense is disallowed in the year of accrual. | Continuous | Sec 43B(h) |
| Advance tax | 15 / 45 / 75 / 100 percent. Factor in Q4 inventory write-down and scrap impact when running the projection. | Quarterly | Sec 208–211 |
| Sec 32 — depreciation | Plant and machinery (corrugating board, flexo printer) at 15% WDV; 20% additional under 32(1)(iia) for new manufacturing P&M put to use; computers at 40%. | Annual | Sec 32 |
| Cash payment cap (40A(3)) | Cash payment above Rs 10,000 disallowed. Applies to scrap purchases and daily-wage labour. | Continuous | Sec 40A(3) |
| ITR filing | ITR-5 / ITR-6. | 31 Oct 2027 | Sec 139(1) |
TDS payments are due by the 7th of the next month (March is 30 April), and quarterly Form 26Q or 27EQ returns drive Form 16 / 16A on TRACES. Late filing of the return alone costs Rs 200 per day under Sec 234E.
| KPI / Compliance Item | Threshold & Action | Due Date | Source |
|---|---|---|---|
| 194Q — Purchase of kraft paper / reels | 0.1% on purchases above Rs 50 lakh from one supplier in the FY (turnover above Rs 10 crore). Kraft mills are usually large suppliers. | 7th of next month | Sec 194Q |
| 194C — Job-work, printing, lamination | 1% / 2% on payments above Rs 30,000 single bill or Rs 1 lakh aggregate. | 7th of next month | Sec 194C |
| 194I — Factory shed rent | 10% on rent above Rs 2.4 lakh in the FY. | 7th of next month | Sec 194I |
| 194J — Quality, R&D, consultant | 10% on professional fees above Rs 30,000. | 7th of next month | Sec 194J |
| 206C(1H) — Sale of finished cartons | 0.1% on sale above Rs 50 lakh from one buyer (seller turnover above Rs 10 crore). Overridden if the buyer deducts under 194Q. | 7th of next month | Sec 206C(1H) |
| Quarterly returns and Form 16 / 16A | Quarterly Form 26Q and 27EQ plus annual TDS certificates from TRACES. | 31 Jul, 31 Oct, 31 Jan, 31 May | Rule 31 / 31A / 31AA |
GST is the most data-rich compliance regime — every invoice you raise and every invoice you receive sits on the network. Use GSTR-2B, not 2A, as your reconciliation base from FY 2022-23 onwards.
| KPI / Compliance Item | Threshold & Action | Due Date | Source |
|---|---|---|---|
| Output HSN 4819 — Corrugated cartons | 18%. | Continuous | Notification 1/2017-CT(R) Sch III |
| Input HSN 4804 — Kraft paper | 18%, same as output. Potential ITC accumulation in some month-classes. | Continuous | Notification 1/2017-CT(R) Sch III |
| Job-work outbound (sending sheets for printing) | 12%. Goods must move under Form ITC-04 quarterly intimation. | Continuous | Notification 11/2017-CT(R) and Rule 45 |
| Inverted duty refund — Sec 54(3)(ii) | Refund of accumulated ITC where input rate exceeds output rate, capped per Rule 89(5). File RFD-01 within 2 years from the end of the FY in which credit accumulated. | Within 2 years | Sec 54(3) and Rule 89(5) |
| E-invoicing | Mandatory if aggregate turnover above Rs 5 crore in any FY since 2017-18. | Every B2B invoice | Rule 48(4) |
| E-way bill | On every dispatch above Rs 50,000, including job-work transit (cross-reference Form ITC-04). | Pre-movement | Rule 138 |
| GSTR-1 / 3B | Monthly. | 11th / 20th | Sec 37 / 39 |
| GSTR-9 / 9C | Annual return plus reconciliation if turnover above Rs 5 crore. | 31 Dec 2027 | Sec 44 |
| Form ITC-04 | Quarterly if turnover above Rs 5 crore, half-yearly otherwise. For job-work goods sent and received back. | 25th of month after period | Rule 45 / Notification 35/2021 |
Profession Tax is a state levy run by the Maharashtra Goods & Services Tax Department. There are two registrations and most businesses need both — one for the owner, one for the staff.
| Registration | Who needs it / what you pay | Due date | Source |
|---|---|---|---|
| PTEC (Enrolment) |
For the proprietor, partner, director, LLP or company. Flat Rs 2,500 per year for most non-salaried professions and businesses. | 30 June | MahaGST PT Act 1975 |
| PTRC (Registration) |
For employers paying salary above Rs 7,500 p.m. (male) or Rs 25,000 p.m. (female). Slabs: Rs 175 p.m. for Rs 7,501–10,000 (male); Rs 200 p.m. plus Rs 300 in February if salary exceeds Rs 10,000. Annual ceiling Rs 2,500 per employee. | Last day of the next month | MahaGST PT Rules |
If your previous-year PT liability crossed Rs 1 lakh, file PTRC monthly. Below that, annual is fine. Returns go on mahagst.gov.in. Late filing costs Rs 1,000 per return plus 1.25% interest a month.
Section 44AA of the Income Tax Act and Section 35 (read with Rule 56) of the CGST Act set the bookkeeping baseline. For most non-professional businesses, books are required if income is above Rs 2.5 lakh or turnover above Rs 25 lakh in any of the three preceding years.
One folder per FY, with sub-folders: sales invoices, purchase invoices, bank statements, GST returns, TDS challans and returns, ROC filings, expense bills, statutory dues, loan documents, fixed asset purchases. Scan everything within 30 days. Scanned PDFs are accepted as books under Rule 6F(5) and CGST Rule 56(15).
The four mistakes our team sees most often when we take over books from another firm:
43B(h) treats the unpaid amount as disallowed irrespective of accrual method. Maintain a vendor master tagged with Udyam category and auto-flag invoices crossing 45 days.
RFD-01 has to be filed within 2 years from the end of the FY of accumulation. Many small units lose 18% on kraft paper purchases simply by not filing in time.
Goods sent for job-work but not received back within 1 year (capital goods: 3 years) are deemed supply on the original date. Interest plus tax becomes payable. ITC-04 plus physical reconciliation is the only defence.
A typical 30-worker unit triggers both PTRC (employer) and PTEC (proprietor). PTRC monthly liability above Rs 1 lakh in the previous FY means monthly returns. Skipping these costs Rs 1,000 per return in penalty.
| Month | Compliance milestones |
|---|---|
| April | TDS payment for March (30 Apr); GSTR-1 / 3B for March; PT employee deduction. |
| May | Q4 TDS return Form 26Q (31 May); Form 16A; SFT-005 / 61A (31 May). |
| June | Form 16 to employees (15 Jun); Q1 advance tax (15 Jun); PTEC payment (30 Jun). |
| July | Q1 TDS return (31 Jul); ITR for non-audit cases (31 Jul); QRMP option last month. |
| August | Routine GSTR-1 / 3B; e-invoice review. |
| September | Tax audit report u/s 44AB (30 Sep); Form 10B / 10BB (30 Sep) for trusts; Q2 advance tax (15 Sep). |
| October | Q2 TDS return (31 Oct); ITR for audit cases (31 Oct); GSTR-9 prep starts. |
| November | ITR for transfer-pricing cases (30 Nov). |
| December | Q3 advance tax (15 Dec); GSTR-9 / 9C filing (31 Dec). |
| January | Q3 TDS return (31 Jan); books reconciliation for FY closing. |
| February | Stock-take preparation; PT special slab (Rs 300 in Feb). |
| March | Q4 advance tax (15 Mar); Annexure V for GTAs (31 Mar); books closure; year-end TDS. |
Talk to our compliance team. We work with contractors, traders, hotels, hospitals, transporters and manufacturers across Maharashtra.
Book a Free ConsultationLedger Logic advises businesses across Bhusawal, Mumbai and Pune on Income Tax, TDS, GST, Profession Tax and statutory bookkeeping. The points above are general guidance — please consult your CA before acting on a specific transaction.