CHAPTER 9

REGISTRATION
The section numbers referred to in the Chapter pertain to CGST Act, 2017, unless
otherwise specified. Examples/Illustrations/Questions and Answers given in the
Chapter are based on the position of GST law existing as on 30.04.2025.

LEARNING OUTCOMES
This Chapter will equip you to –
 understand the concept of the taxable person.
 explain when a person becomes liable to get registered under
GST.
 identify the scenarios where registration is compulsory.
 identify the persons who are not liable for registration.
 describe the procedure for obtaining registration under GST.
 explain the procedure for amendment of registration.
 describe the cancellation of registration and revocation of
cancellation of registration in specified circumstances.

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 9.2 GOODS AND SERVICES TAX

CHAPTER OVERVIEW

Persons liable for registration

Compulsory registration in certain cases

Persons not liable for registration

Registration

Procedure for registration

Amendment of registration

Cancellation of registration

Revocation of cancellation of registration

1. INTRODUCTION
Under any taxation law, registration is the most
fundamental requirement for identification of tax payers
ensuring tax compliance in the economy. It is the first
step towards becoming GST complaint. Under indirect tax
regime, without registration, a person can neither collect
tax from his customers nor claim any credit of tax paid by
him.
Registration legally recognizes a person as supplier of goods
or services or both and legally authorizes him to collect taxes
from his customers and pass on the credit of the taxes paid
on the goods or services supplied to the
purchasers/recipients. He can claim the input tax credit of taxes
paid and can utilize the same for payment of taxes due on PAN based
supply of goods or services. Registration ensures the seamless registration

flow of input tax credit from suppliers to recipients at the

national level.

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 REGISTRATION 9.3

Under GST law, a supplier is required to obtain State-wise registration. There is no

concept of a centralized registration under GST like the erstwhile service tax regime.
A supplier has to obtain registration in every State/UT from where he makes a
taxable supply provided his aggregate turnover exceeds a specified threshold limit.
Thus, he is not required to obtain registration from a State/UT from where he makes
a non-taxable supply.
Since registration in GST is PAN based, once a supplier is liable to register, he has
to obtain registration in each of the States/UTs in which he operates under the
same PAN. Further, he is normally required to obtain single registration in a
State/UT. However, where he has multiple places of business in a State/UT, he has
the option either to get a single registration for said State/UT [wherein it can
declare one place as principal place of business (PPoB) and other branches as
additional place(s) of business (APoB)] or to get separate registrations for each
place of business in such State/UT.
Registration under GST is not tax specific, which means that there is single
registration for all the taxes i.e. CGST, SGST/UTGST, IGST and GST compensation
cess.
Chapter VI - Registration [Sections 22 to 30] of the CGST Act and Chapter III –
Registration [Rules 8 to 26] of the CGST Rules contain the provisions relating to
registration. State GST laws also prescribe identical provisions in relation to
Registration.

Provisions of registration under CGST Act have also been made applicable to
IGST Act vide section 20 of the IGST Act.

Before proceeding to understand the registration provisions, let us first go

through few relevant definitions.

2. RELEVANT DEFINITIONS
 Agent: means a person, including a factor, broker, commission agent,
arhatia, del credere agent, an auctioneer or any other mercantile agent,
by whatever name called, who carries on the business of supply or receipt
of goods or services or both on behalf of another [Section 2(5)].

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 9.4 GOODS AND SERVICES TAX

 Common portal: means the common goods and services tax electronic
portal referred to in section 146 [Section 2(26)].
 Taxable supply: means a supply of goods or services or both which is
leviable to tax under this Act [Section 2(108)].
 Taxable territory: means the territory to which the provisions of this Act
apply [Section 2(109)].
 Place of business: includes [Section 2(85)]:

a place from where the business is ordinarily carried on, and includes a
warehouse, a godown or any other place where a taxable person stores his
goods, supplies or receives goods or services or both; or

a place where a taxable person maintains his books of account; or

a place where a taxable person is engaged in business through an agent,

by whatever name called.

 Appellate Authority: means an authority appointed or authorised to hear

appeals as referred to in section 107 1 [Section 2(8)].
 Fixed establishment: means a place (other than the registered place of
business) which is characterised by a sufficient degree of permanence and
suitable structure in terms of human and technical resources to supply
services, or to receive and use services for its own needs [Section 2(50)].
 Principal place of business: means the place of business specified as the
principal place of business in the certificate of registration [Section 2(89)].
 Proper officer: in relation to any function to be performed under this Act,
means the Commissioner or the officer of the central tax who is assigned
that function by the Commissioner in the Board [Section 2(91)].
 Registered person: means a person who is registered under section 25,
but does not include a person having a Unique Identity Number [Section
2(94)].
 Tax period: means the period for which the return is required to be
furnished [Section 2(106)].

1
Section 107 contains the provisions relating to ‘Appeals to Appellate Authority’. The same shall
be discussed in detail at final level.

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 REGISTRATION 9.5

 Business: includes [Section 2(17)]–

(a) any trade, commerce, manufacture, profession, vocation, adventure, wager or

any other similar activity, whether or not it is for a pecuniary benefit;

(b) any activity or transaction in connection with or incidental or ancillary to (a)

above;

(c) any activity or transaction in the nature of (a) above, whether or not there is
volume, frequency, continuity or regularity of such transaction;

(d) supply or acquisition of goods including capital assets and services in

connection with commencement or closure of business;

(e) provision by a club, association, society, or any such body (for a subscription
or any other consideration) of the facilities or benefits to its members, as the
case may be;

(f) admission, for a consideration, of persons to any premises;

(g) services supplied by a person as the holder of an office which has been
accepted by him in the course or furtherance of his trade, profession or vocation;

(h) activities of a race club including by way of totalisator or a license to book

maker or activities of a licensed book maker in such club; and

(i) any activity or transaction undertaken by the Central Government, a State

Government or any local authority in which they are engaged as public
authorities.

3. CONCEPT OF TAXABLE PERSON [SECTION

2(107)]
Under GST law, the concept of taxable person is significant
since tax on supplies of goods
and/or services, is to be paid by a
taxable person. So, let us
understand the concept of taxable
person. As per section 2(107),
taxable person means a person

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 9.6 GOODS AND SERVICES TAX

who is registered or liable to be registered under section 22 or section 24 [These

sections have been discussed in detail subsequently in this Chapter].
Thus, even an unregistered person who is liable to be registered is a taxable person.
Similarly, a person not liable to be registered, but has taken voluntary registration
and got himself registered is also a taxable person.
In the subsequent paras, we will see when does a person becomes liable to get
registered, what is the procedure for getting registered under GST and how to get
the registration application amended, when can registration be cancelled and when
the cancellation of the registration by the Department or by the registered person
be revoked.
Following sections of Chapter VI – Registration of the CGST Act shall be discussed
in this chapter to understand the registration provisions:

Section 22 Persons liable for registration.

Section 23 Persons not liable for registration

Section 24 Compulsory registration in certain cases

Section 25 Procedure for registration.

Section 26 Deemed registration

Section 27 Special provisions relating to casual taxable person and

non-resident taxable person

Section 28 Amendment of registration

Section 29 Cancellation or suspension of registration

Section 30 Revocation of cancellation of registration

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 REGISTRATION 9.7

4. PERSONS LIABLE FOR REGISTRATION

[SECTION 22]

STATUTORY PROVISIONS

Section 22 Persons liable for registration

(Relevant
Extract)
Sub-section Particulars
(1) Every supplier shall be liable to be registered under this Act in the
State or Union territory, other than special category States, from
where he makes a taxable supply of goods or services or both, if his
aggregate turnover in a financial year exceeds twenty lakh rupees.
Provided that where such person makes taxable supplies of goods
or services or both from any of the special category States, he shall
be liable to be registered if his aggregate turnover in a financial
year exceeds ten lakh rupees.
Provided further that the Government may, at the request of a
special category State and on the recommendations of the Council,
enhance the aggregate turnover referred to in the first proviso from
ten lakh rupees to such amount, not exceeding twenty lakh rupees
and subject to such conditions and limitations, as may be so
notified.
Provided also that the Government may, at the request of a State
and on the recommendations of the Council, enhance the
aggregate turnover from twenty lakh rupees to such amount not
exceeding forty lakh rupees in case of supplier who is engaged
exclusively in the supply of goods, subject to such conditions and
limitations, as may be notified.
Explanation––For the purposes of this sub-section, a person shall
be considered to be engaged exclusively in the supply of goods even
if he is engaged in exempt supply of services provided by way of
extending deposits, loans or advances in so far as the consideration
is represented by way of interest or discount.

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 9.8 GOODS AND SERVICES TAX

(2) Every person who, on the day immediately preceding the

appointed day, is registered or holds a license under an existing
law, shall be liable to be registered under this Act with effect
from the appointed day.
(3) Where a business carried on by a taxable person registered
under this Act is transferred, whether on account of succession
or otherwise, to another person as a going concern, the
transferee or the successor, as the case may be, shall be liable to
be registered with effect from the date of such transfer or
succession.
(4) Notwithstanding anything contained in sub-sections (1) and (3),
in a case of transfer pursuant to sanction of a scheme or an
arrangement for amalgamation or, as the case may be, de-
merger of two or more companies pursuant to an order of a High
Court, Tribunal or otherwise, the transferee shall be liable to be
registered, with effect from the date on which the Registrar of
Companies issues a certificate of incorporation giving effect to
such order of the High Court or Tribunal.
Explanation 2––For the purposes of this section, ––
(i) the expression “aggregate turnover” shall include all
supplies made by the taxable person, whether on his
own account or made on behalf of all his principals
(iii) the expression “special category States” shall mean
the States as specified in sub-clause (g) of clause (4)
of article 279A of the Constitution except the State of
Jammu and Kashmir and States of Arunachal Pradesh,
Assam, Himachal Pradesh, Meghalaya, Sikkim and
Uttarakhand.

ANALYSIS

2
Clause (ii) to Explanation relates to ‘Job work’. The same shall be discussed in detail at final level.

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 REGISTRATION 9.9

(i) Threshold limit for registration

 Every supplier of goods or services or both is required to obtain
registration
 in the State or the Union territory from where he makes the taxable
supply
 if his aggregate turnover exceeds specified threshold limit in a FY.
Aggregate Turnover

Before, we study what is the applicable threshold

limit for various States/ UTs, let us first
understand the concept of aggregate turnover.
Aggregate turnover is a crucial parameter for
deciding the eligibility of a supplier to avail the
benefit of threshold exemption from registration,
eligibility for composition scheme [Discussed in
Chapter 3 – Charge of GST].
‘Turnover’ in common parlance is the total
volume of business. The term ‘aggregate turnover’ as defined under section
2(6) has been presented in the diagrammatic form as follows:

Aggregate turnover

Includes Excludes
Value of all outward supplies
--Taxable supplies --CGST/ SGST/ UTGST/ IGST/
--Exempt supplies Cess
--Exports --Value of inward supplies on
--Inter-State supplies which tax is payable under
of persons having the same PAN to reverse charge.
be computed on all India basis.

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 9.10 GOODS AND SERVICES TAX

Section 2(6) [definition of ‘aggregate turnover’ as given above] read with

explanation (i) to section 22 has been analysed as follows:
(A) Aggregate turnover to exclude inward supplies on which tax is
payable under reverse charge: It may be noted that the inward
supplies on which recipient is required to pay tax under Reverse Charge
Mechanism (RCM) do not form part of the ‘aggregate turnover’. The
law stipulates certain supplies like, Goods Transport Agency services,
legal services, sponsorship services, to name a few, where the recipient
of service is made to pay the tax – Discussed in detail in Chapter 3 –
Charge of GST. The value of such supplies would not form part of the
‘aggregate turnover’ of recipient of such supplies.

Outward Supplies taxable

under reverse charge would
continue to be part of the
‘aggregate turnover’ of the
supplier of such supplies

(1) Raghubir Private Ltd. pays GST on sitting fees paid to its
directors for the services rendered by them, taxable under
reverse charge. Value of services provided by the directors to
Raghubir Private Ltd. will form part of the aggregate turnover of the
directors and not of Raghubir Private Ltd.
(B) Aggregate turnover excludes the element of CGST, SGST, UTGST,
and IGST and compensation cess.
(C) Aggregate turnover to include total turnover of all branches (i.e.
all GST registrations) under same PAN
Aggregate turnover is calculated by taking together the value in respect
of the activities carried out on all-India basis.
(2) A dealer ‘X’ has two offices – one in Delhi and another in
Haryana. In order to determine whether ‘X’ is liable for
registration, turnover of both the offices would be taken into
account and only if the same exceeds the applicable threshold limit, X is
liable for registration subject to provisions of section 24.

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(D) Value of exported goods/services, exempted goods/services, inter-

State supplies between distinct persons having same PAN, to be
included in aggregate turnover.
(3) Madhur Oils, Punjab, is engaged in supplying machine
oil as well as petrol. Supply of petrol is not leviable to GST,
but supply of machine oil is taxable. In order to determine
whether Madhur Oils is liable for registration, turnover of both non-
taxable 3 as well as taxable supplies would be taken into account and if
the same exceeds the applicable threshold limit, Madhur Oils is liable
for registration.
(E) Aggregate turnover to include all supplies made by the taxable
person, whether on his own account or made on behalf of all his
principals.
(4) Mohini Enterprises has appointed M/s Bestfords &
Associates as its agent. M/s Bestfords & Associates makes
supply of goods on its own account and, on behalf of Mohini
Enterprises where invoices are issued in name of M/s Bestfords &
Associates only.
All the supplies of goods made by M/s Bestfords & Associates as agent
of Mohini Enterprises as well as on its own account will be included in
the aggregate turnover of M/s Bestfords & Associates.
(F) ‘Aggregate turnover’ Vs. ‘Turnover in a State’: The aggregate
turnover is different from turnover in a State. The former is used for
determining the threshold limit for registration and eligibility for
composition scheme [Discussed in Chapter 3 – Charge of GST].
However, once a person is eligible for composition levy, the GST
payable under composition levy would be calculated as a specified %
of ‘turnover in the State/UT’.
Applicable threshold limit
The threshold limit prescribed under section 22(1) is ` 20 lakh in a FY, i.e.
every supplier, whose aggregate turnover in a financial year exceeds ` 20 lakh,
is liable to be registered under GST in the State/ Union territory from where
he makes the taxable supply of goods and/or services.

3
Exempt supply includes non-taxable supply as per section 2(47).

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However, the limit of ` 20 lakh will be reduced to ` 10 lakh if the person is

carrying out business in Special Category States. As per Article 279A(4)(g)
of the Constitution, there are 11 Special Category States, namely, States of
Arunachal Pradesh, Assam, Jammu and Kashmir 4, Manipur, Meghalaya,
Mizoram, Nagaland, Sikkim, Tripura, Himachal Pradesh and Uttarakhand.
However, as per the explanation (iii) to section 22, for the purposes of
registration, only Mizoram, Tripura, Manipur and Nagaland are Special
Category States. Therefore, the threshold limit ` 10 lakh is applicable for
Mizoram, Tripura, Manipur and Nagaland.

If a person with places of business in

different States across India has one
branch in a Special Category State
from which it makes a taxable supply,
the threshold limit for GST registration
will be reduced to ` 10 lakh.

Government is empowered to enhance the threshold limit of ` 20 lakh upto

` 40 lakh for a supplier engaged exclusively in the supply of goods, at the
request of a State and on the recommendations of the Council. This shall be
subject to such conditions and limitations, as may be notified.
For the purposes of section 22(1), a person shall be considered to be engaged
exclusively in the supply of goods even if he is engaged in exempt supply of
services provided by way of extending deposits, loans or advances in so far
as the consideration is represented by way of interest or discount.
Further, Notification No. 10/2019 CT dated 07.03.2019 exempts any
person who is engaged in exclusive supply of goods and whose
aggregate turnover in the financial year does not exceed ` 40 lakh, from
registration requirement.
Exceptions to this exemption are as follows:
(a) Persons required to take compulsory registration under section 24.

4
The erstwhile State of Jammu and Kashmir was reorganised into the Union territory of Jammu
and Kashmir (with Legislature) and Union territory of Ladakh vide the Jammu and Kashmir
Reorganisation Act, 2019.

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 REGISTRATION 9.13

(b) Persons engaged in making supplies of

(i) ice cream and other edible ice, whether or not containing cocoa
[2105 00 00],
(ii) pan masala [2106 90 20],
(iii) all goods of Chapter 24, i.e. Tobacco and manufactured tobacco
substitutes,
(iv) fly ash bricks; fly ash aggregates; fly ash blocks [6815],
(v) bricks of fossil meals or similar siliceous earths [6901 00 10],
(vi) building bricks [6904 10 00],
(vii) earthen or roofing tiles [6905 10 00].
(c) Persons engaged in making intra-State supplies in the States of
Arunachal Pradesh, Uttarakhand, Meghalaya, Sikkim, Telangana,
Puducherry and Special Category States as per section 22 [Nagaland,
Mizoram, Manipur, Tripura]. Inter-State supplies of goods are
nevertheless liable to compulsory registration and are already covered
in exception (a) above.
(d) Person who has opted for voluntary registration or such registered
persons who intend to continue with their registration under the CGST Act.
In view the above discussion, the registration requirements under GST can be
summarised as follows:

Threshold limit for persons

engaged
exclusively in exclusively in
supply of supply of
goods services/ both
goods &
services
States/UTs other than Puducherry ` 20 lakh ` 20 Lakh
Special Category
Telangana ` 20 lakh ` 20 Lakh
States
Others ` 40 lakh ` 20 Lakh
Manipur ` 10 lakh ` 10 Lakh

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 9.14 GOODS AND SERVICES TAX

Special Special Mizoram ` 10 lakh ` 10 Lakh

Category Category
Nagaland ` 10 lakh ` 10 Lakh
States/ States as
UTs as per Tripura ` 10 lakh ` 10 Lakh
per section 22
Constitu
Other Jammu and ` 40 lakh ` 20 Lakh
tion
States/UTs Kashmir
Assam ` 40 lakh ` 20 Lakh
Himachal ` 40 lakh ` 20 Lakh
Pradesh
Arunachal ` 20 Lakh ` 20 Lakh
Pradesh
Meghalaya ` 20 Lakh ` 20 Lakh
Sikkim ` 20 Lakh ` 20 Lakh
Uttarakhand ` 20 Lakh ` 20 Lakh

States with States/UTs with States/UTs with threshold

threshold limit of threshold limit of limit of ` 20 lakh for
supplier of services/ both
` 10 lakh for ` 20 lakh for
goods and services and ` 40
supplier of goods supplier of goods lakh for supplier of goods
and/or services and/or services (Intra-State)
Arunachal
Jammu and
Manipur Pradesh
Kashmir
Meghalaya
Mizoram Assam
Sikkim

Uttarakhand Himachal
Nagaland
Pradesh
Puducherry
Tripura All other States
Telangana

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 REGISTRATION 9.15

(5) Prithiviraj of Assam is exclusively engaged in intra-State supply

of shoes. His aggregate turnover in the current financial year is
` 22 lakh. In view of the discussion in the above paras, the applicable
threshold limit for registration for Prithviraj in the given case is ` 40 lakh. Thus,
he is not liable to get registered under GST.
If in above example, all other things remaining the same, Prithiviraj is exclusively
engaged in supply of pan masala instead of shoes, he will not be eligible for
higher threshold limit of ` 40 lakh and the applicable threshold limit for
registration in that given case will be ` 20 lakh. Thus, Prithiviraj will be liable to
get registered under GST.

If instead of pan masala, Prithiviraj is exclusively engaged in supply of taxable

services, the applicable threshold limit for registration will still be ` 20 lakh. Thus,
Prithiviraj will be liable to get registered under GST.

Further, if Prithiviraj is engaged in supply of both taxable goods and services, the
applicable threshold limit for registration will be ` 20 lakh only. Thus, Prithiviraj
will be liable to get registered under GST.

(6) Shivaji of Telangana is exclusively engaged in intra-State supply

of toys. Its aggregate turnover in the current financial year is ` 22
lakh. Since Shivaji is making taxable supplies from Telangana, he will
not be eligible for higher threshold limit available in case of exclusive supply of
goods. The applicable threshold limit for registration for Shivaji in the given case
is ` 20 lakh. Thus, he is liable to get registered under GST.

If in above example, all other things remaining the same, Shivaji is exclusively
engaged in supply of taxable services instead of toys, the applicable threshold
limit for registration will still be ` 20 lakh. Thus, Shivaji will be liable to get
registered under GST.
Further, if Shivaji is engaged in supply of both taxable goods and services, the
applicable threshold limit for registration will be ` 20 lakh only. Thus, Shivaji will
be liable to get registered under GST.
(7) Ashoka of Manipur is exclusively engaged in intra-State supply of
paper. Its aggregate turnover in the current financial year is
` 12 lakh. Since Ashoka is making taxable supplies from Manipur
which is a Special Category State, the applicable threshold limit for registration

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for Ashoka in the given case is ` 10 lakh. Thus, he is liable to get registered
under GST.
If in above example, all other things remaining the same, Ashoka is exclusively
engaged in supply of taxable services instead of paper, the applicable threshold
limit for registration will still be ` 10 lakh. Thus, Ashoka will be liable to get
registered under GST.
Further, if Ashoka is engaged in supply of both taxable goods and services, the
applicable threshold limit for registration in that given case will be ` 10 lakh only.
Thus, Ashoka will be liable to get registered under GST.
(8) Raghav of Assam is exclusively engaged in intra-State supply of
readymade garments. His turnover in the current F.Y. from Assam
showroom is ` 28 lakh. He has another showroom in Tripura with a
turnover of ` 11 lakh in the current F.Y. Since Raghav is engaged in supplying
garments from a Special Category State as per section 22, the applicable
threshold limit for him gets reduced to ` 10 lakh. Further, Raghav is liable to get
registered under GST in both Assam and Tripura on his aggregate turnover
crossing the threshold limit of ` 10 lakh.
(ii) Registration to be obtained only for a place of business from where
taxable supply takes place
A supplier is required to obtain registration with respect to his each place of
business in India from where a taxable supply has been made. However, a
supplier is not liable to obtain registration in a State/UT from where he makes
an exempt/non-taxable supply.

It is pertinent to note here that a supplier is required to obtain registration

only in the State(s) “from where taxable supply is made” and not “where
taxable supply is made”. It may be noted that if goods and/or services are
supplied in different States, GST registration is not required in each such
State(s).
Thus, if a person has only liaison office or marketing office in a State and if
there is no taxable supply from that State, he is not required to obtain
registration in that State, even if he is registered in other State/s. Thus, in that
State where liaison office or marketing office is located, he will be treated as
‘unregistered’.

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 REGISTRATION 9.17

(9) Mr. X has a registered office in Delhi. He imports goods which

are landed at Mumbai sea port. Mr. X enters into a sales agreement
with Mr. Y located in Mumbai to directly sell the goods from the
Mumbai port. In this case, Mr. X is not required to obtain registration in
Mumbai as he has no fixed establishment in Mumbai.
Further, in a State from where taxable supply has been made, registration is
required to be obtained only if the supplier has a “fixed establishment” in
such State. This aspect is more relevant in respect of supply of services like
repair & maintenance, transportation, security, erection & commissioning
services and construction contracts etc.
Further, the threshold limit of a person having places of business in more than
one State/UT in India gets reduced to ` 10 lakh only when such person makes
taxable supplies of goods or services or both from any of the Special
Category States as per section 22. However, in case he makes exempt/non-
taxable supply from a Special Category State and taxable supplies from a
State other than Special Category State, the threshold limit shall not be so
reduced.
(10) Uday Enterprises is engaged in supply of taxable goods and
services in Maharashtra. It also supplies alcoholic liquor for human
consumption from Nagaland. Its turnover in the current financial
year is ` 14 lakh in Maharashtra and ` 11 lakh in Nagaland.
Since Uday Enterprises is engaged in making taxable supplies of goods and
services from Maharashtra, the applicable threshold limit for obtaining
registration is ` 20 lakh. However, the threshold limit will not be reduced to
` 10 lakh in this case, as supply of alcoholic liquor for human consumption
from Nagaland (one of the Special Category States) is non-taxable supply 5.
In the given case, since the aggregate turnover of Uday Enterprises exceeds
the applicable threshold limit of ` 20 lakh, it is liable to obtain registration. It
will obtain registration in Maharashtra but is not required to obtain
registration in Nagaland as he is not making any taxable supplies from the
said State.

5
in terms of section 9(1)

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(iii) Person liable for registration in case of transfer of business

Where a business is transferred, whether on account of
succession/any other reason [including transfer/change in
the ownership of business due to death of the sole
proprietor 6], to another person as a going concern, the
transferee/successor, is to be registered with effect from the date of such
transfer/succession. Where the business is transferred, pursuant to sanction
of a scheme/ arrangement for amalgamation/ de-merger of two or more
companies, pursuant to an order of a High Court/Tribunal, the transferee is
to be registered with effect from the date on which the Registrar of
Companies issues a certificate of incorporation giving effect to such order.

5. COMPULSORY REGISTRATION IN CERTAIN

CASES [SECTION 24]
As we have seen above that a supplier is liable to be registered under GST in the
State/ Union territory from where he makes the taxable supply of goods and/or
services only if his aggregate turnover in a financial year exceeds the applicable
threshold limit. However, there are certain cases wherein a supplier is mandatorily
required to obtain registration irrespective of the quantum of his aggregate
turnover. In other words, these are the cases wherein a supplier is compulsorily
required to obtain registration even though his aggregate turnover does not
exceed the applicable threshold limit.
However, certain exemptions from registration have also been provided under
section 23. These exceptions have been incorporated briefly at the relevant places
in the discussion under this heading in order to provide a holistic picture. The
exceptions have also been explained in detail in the next heading 6. Persons not
liable for registration.
The category of persons requiring compulsory registration under GST have been
enlisted below:
(1) Persons making any inter-State taxable supply. However, threshold limit
of ` 20 lakh (` 10 lakh in case of Special Category States of Mizoram, Tripura,

6
clarified vide Circular No. 96/15/2019 GST dated 28.03.2019

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 REGISTRATION 9.19

Manipur and Nagaland) is available in case of inter-State supply of taxable

services and of notified handicraft goods.
(2) Casual taxable persons (CTP) making taxable supply. However, threshold
limit of ` 20 lakh (` 10 lakh in case of Special Category States of Mizoram,
Tripura, Manipur and Nagaland) is available in case of CTP who is making
inter-State taxable supplies of notified handicraft goods and availing the
benefit of exemption from registration as mentioned in point (1) above.
(3) Persons who are required to pay tax under reverse charge on inward
supplies received. However, persons engaged exclusively in making
outward supplies, tax on which is liable to be paid on reverse charge basis
under section 9(3) [except suppliers of metal scrap (Chapter 72 to 81)] are
exempt from registration.
(4) Non-resident taxable persons (NRTP) making taxable supply.
(5) E-commerce:
(i) Every ECO (Electronic Commerce Operator) who is required to collect
tax at source under section 52.
(ii) Persons who are required to pay tax under section 9(5) 7 i.e. e-commerce
operator who is required to pay tax on specified services.
(iii) Persons who supply goods and/or services, other than supplies
specified under section 9(5), through such ECO who is required to
collect TCS under section 52. Exceptions are as follows:
 The threshold limit of ` 20 lakh (` 10 lakh in case of Special
Category States of Mizoram, Tripura, Manipur and Nagaland) is
available in case of suppliers supplying services through ECO.
 The threshold limit for registration is available to persons making
intra-State supplies of goods through ECO.
(6) Persons who are required to deduct tax under section 51, whether or not
separately registered under this Act.

7
The provisions of section 9(5) of the CGST Act, 2017 where the ECO is required to pay tax are
discussed in detail in Chapter 3 – Charge of GST in Module 1 of this Study Material.

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 9.20 GOODS AND SERVICES TAX

(7) Persons who make taxable supply of goods or services or both on behalf of
other taxable persons whether as an agent or otherwise.
(8) Input Service Distributor, whether or not separately registered under this Act.
(9) Every person supplying online information and data base access or retrieval
(OIDAR) services from a place outside India to a person in India, other than a
registered person 8.
(10) every person supplying online money gaming from a place outside India to a
person in India
(11) such other person or class of persons as may be notified by the Government
on the recommendations of the Council.

Note: Concept of CTP and NRTP is explained subsequently in this chapter.

6. PERSONS NOT LIABLE FOR REGISTRATION

[SECTION 23]
(i) Persons not liable to registration
Section 23 lists the persons who are not liable to registration. Thus, the persons
so listed will not be the ‘taxable persons’.
(A) Person engaged exclusively in the business of supplying goods and
/or services not liable to tax/wholly exempt from tax: As per
section 23, any person engaged exclusively in the business of supplying
goods or services or both that are not liable to tax or wholly exempt from
tax under CGST Act/IGST Act shall not be liable to registration. This
provision can be understood with the help of following examples:
(11) Madhur Oils, Punjab, is exclusively engaged in supplying
petrol. Supply of petrol is not leviable to GST. Thus, Madhur Oils
is not liable for registration as it is engaged exclusively in supplying
goods not leviable to tax.

8
The provisions relating to Input Service Distributor, OIDAR services and supply of service of
online money gaming from a place outside India to a person in India will be discussed in
detail at the Final Level. Hence, text shaded in blue here is only for the purpose of knowledge
of the students and is not relevant for the examinations.

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 REGISTRATION 9.21

(12) Bhavyajyoti Foundation, a charitable trust registered under

section 12AA of the Income-tax Act, 1961, is exclusively engaged
in supply of services by way of charitable activities. Services by an
entity registered under section 12AA of the Income-tax Act, 1961 by way of
charitable activities are exempt from GST. Thus, Bhavyajyoti Foundation is
not liable for registration as it is exclusively engaged in supplying services
exempt from tax.
(B) An agriculturist, to the extent of supply of produce out of cultivation
of land: An agriculturist to the extent of supply of
produce out of cultivation of land is also not liable to
registration. The term agriculturist has been defined
under section 2(7) as an individual/Hindu Undivided
Family (HUF) who undertakes cultivation of land—
(a) by own labour, or
(b) by the labour of family, or
(c) by servants on wages payable in cash or kind or by
hired labour under personal supervision or the
personal supervision of any member of the family.
From the above definition, it is clear that the benefit of not being liable to
registration is only restricted to the agriculturists who are individuals or
HUFs. Further, if an agriculturist is also engaged in making any supply
other than supply of produce out of cultivation of land, he shall be liable
to registration based on applicable threshold limit.
(13) Deshbandhu is an agriculturist engaged in cultivation of
wheat in his field in the State of Punjab. He was exclusively
engaged in intra-State supply of wheat cultivated in his field in the
previous year. Thus, he was not liable to registration as he was exclusively
engaged in supply of produce out of cultivation of land.

In the current year, he decided to start trading in pre-packaged and labelled

puffed rice apart from supplying his wheat produce. His turnover in the
current year is ` 32 lakh from supply of wheat produced and ` 9 lakh from
trading of pre-packaged and labelled puffed rice.

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 9.22 GOODS AND SERVICES TAX

Since he is engaged in trading of pre-packaged and labelled puffed rice also,

he is not covered under section 23 above. The threshold limit for registration
applicable to a person exclusively engaged in supply of goods in the State of
Punjab is ` 40 lakh. The aggregate turnover of Deshbandhu in the current
year is ` 41 lakh [` 32 lakh + ` 9 lakh] which exceeds the threshold limit. Thus,
he will be liable to registration.
(ii) Specified category of persons notified by the Government exempted
from obtaining registration
Notwithstanding anything to the contrary contained in sub-section (1) of
section 22 or section 24, the Government may, on the recommendations of
the Council, by notification, subject to such conditions and restrictions as may
be specified therein, specify the category of persons who may be exempted
from obtaining registration under this Act.

The following category of persons have been notified as being exempted

from obtaining registration under GST law:
A. Persons making only reverse charge supplies
Persons who are only engaged in making supplies of taxable goods or
services or both, the total tax on which is liable to be paid on reverse
charge basis by the recipient of such goods or services or both under
section 9(3) have been exempted from obtaining registration.
However, nothing contained in this notification shall apply to any
person engaged in the supply of metal scrap, falling under Chapters 72
to 81 in the first schedule to the Customs Tariff Act, 1975.
[Notification No. 5/2017 CT dated 19.06.2017]
(14) Manikaran Transporters is a Goods Transport Agency
(GTA) engaged exclusively in supplying GTA services liable
to tax under reverse charge [since tax is being paid on GTA
services @ 5% and Manikaran has not exercised the option to pay GST
itself in the given case]. Thus, it is exempt from registration as it is
engaged exclusively in making supplies, tax on which is liable to be paid
on reverse charge basis.

Further, Manikaran Transporters supplies said service to Diwakar

Manufacturing Pvt. Ltd. whose aggregate turnover does not exceed the

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 REGISTRATION 9.23

applicable threshold limit. However, since Diwakar Manufacturing Pvt.

Ltd. has to pay tax on GTA services [@ 5%] under reverse charge, it is
required to obtain registration mandatorily irrespective of its aggregate
turnover.
B. Persons making inter-State supplies of taxable services up to ` 20
lakh
The persons making inter-State supplies of taxable services and having
an aggregate turnover, to be computed on all India basis, not exceeding
an amount of ` 20 lakh in a financial year have been exempted from
obtaining compulsory registration. However, the aggregate value of
such supplies, computed on all India basis, should not exceed an
amount of ` 10 lakh in case of Special Category States of Mizoram,
Tripura, Manipur and Nagaland [Notification No. 10/2017 IT dated
13.10.2017].
(15) Dhola & Co., located in Delhi, is engaged in supply of
taxable goods 9 in the neighbouring States of Punjab and
Haryana. Its aggregate turnover in current FY is ` 10 lakh.
Since it is engaged in making inter-State taxable supply of goods, it is
required to register mandatorily under GST irrespective of its aggregate
turnover.
However, if in the above case, Dhola & Co. is engaged in inter- State
supply of taxable services instead of goods, it will be eligible for
exemption from registration till its aggregate turnover does not exceed
` 20 lakh.
C. Persons making inter-State taxable supplies of notified handicraft
goods up to ` 20,00,000
As we have seen earlier that as per section 24 read
with Notification No. 10/2017 IT, a person making
inter-State supplies of goods is liable to be
registered compulsorily under GST irrespective of
the threshold limit.

9
other than notified handicraft goods

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 9.24 GOODS AND SERVICES TAX

However, in the following cases, persons making inter-State supplies

of goods have been exempted from obtaining registration:
(a) Persons making inter-State taxable supplies of notified 10
handicraft goods.
(b) Persons making inter-State taxable supplies of notified
products 11 , when made by craftsmen predominantly by hand even
though some machinery may also be used in the process.
Conditions to be fulfilled:
1. The aggregate value of such supplies, to be computed on all India
basis, does not exceed an amount of ` 20 lakh [` 10 lakh in case of
Special Category States of Mizoram, Tripura, Manipur and
Nagaland] in a FY.
2. Such persons have obtained a PAN and have generated an
e-way bill 12 [Notification No. 3/2018 IT dated 22.10.2018].
(16) Ariza Pvt. Ltd., located in Madhya Pradesh, is a supplier
of taxable and notified handicraft goods. It supplies these
goods in the neighbouring States of Uttar Pradesh and Orissa. Its
aggregate turnover in the month of April is ` 15 lakh. Although Ariza
Pvt. Ltd. is engaged in making inter-State supplies of taxable goods, it
is not liable to obtain registration till its aggregate turnover does not

10
Handicraft goods referred herein are goods as defined and notified in Notification No. 21/2018 CT (R)
dated 26.07.2018. This notification notifies the handicraft items which are eligible for concessional rate
of tax, for instance, handcrafted candles, articles made of paper mache, coir articles, handbags including
pouches and purses; jewellery box, hand embroidered articles, art ware of iron/aluminium, etc. These
examples are only for the purpose of knowledge and are not relevant for examination purposes.
Handicraft goods are defined under said notification as goods predominantly made by hand even though
some tools or machinery may also have been used in the process; such goods are graced with visual
appeal in the nature of ornamentation or in-lay work or some similar work of a substantial nature;
possess distinctive features, which can be aesthetic, artistic, ethnic or culturally attached and are amply
different from mechanically produced goods of similar utility.
11
Some of the notified products are leather articles, carved wood products, wood turning and
lacquer ware, bamboo products, textiles hand printing, theatre costumes, musical instruments, dolls
and toys, etc. These examples are only for the purpose of knowledge and are not relevant for
examination purpose.
12
The provisions relating to e-way bill have been discussed in detail in Chapter 12 in this Module
of the Study Material.

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 REGISTRATION 9.25

exceed ` 20 lakh as it has availed the exemption from registration under

Notification No. 03/2018 IT 13.
D. Casual Taxable Persons making inter-State taxable supplies of
notified handicraft goods up to ` 20 lakh
As we have seen earlier that as per section 24, a CTP is liable to be
registered compulsorily under GST irrespective of the threshold limit.
However, following categories of CTPs have been exempted from
obtaining registration:
(a) CTPs making inter-State taxable supplies of notified handicraft
goods, [as referred in Point C. above] or
(b) CTPs making inter-State taxable supplies of notified products [as
referred in Point C. above], when made by the craftsmen
predominantly by hand even though some machinery may also be
used in the process.
Conditions to be fulfilled:
1. CTPs are availing benefit of Notification No. 03/2018 IT dated
22.10.2018 [discussed above].
2. The aggregate value of such supplies, to be computed on all India
basis, does not exceed an amount of ` 20 lakh [` 10 lakh in case
of Special Category States of Mizoram, Tripura, Manipur and
Nagaland] in a FY.
3. Such persons have obtained a PAN and have generated an
e-way bill [Notification No. 56/2018 CT dated 23.10.2018].
E. Persons making supplies of services through an ECO [other than
supplies specified under section 9(5)] with aggregate turnover up
to ` 20 lakh
Persons making supplies of services, other than supplies specified under
section 9(5), through an ECO who is required to collect tax at source
under section 52, and having an aggregate turnover, to be computed
on all India basis, not exceeding ` 20 lakh (` 10 lakh in case of Special
Category States of Mizoram, Tripura, Manipur and Nagaland) in a FY,

13
subject to fulfilment of other conditions prescribed under said notification.

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 9.26 GOODS AND SERVICES TAX

have been exempted from obtaining compulsory registration

[Notification No. 65/2017 CT dated 15.11.2017].
Therefore, all service providers, whether supplying intra-State,
inter-State or through ECO, will be exempt from obtaining registration,
provided their aggregate turnover does not exceed ` 20 lakh (` 10 lakh
in special category States of Mizoram, Tripura, Manipur and Nagaland).
F. Persons making intra-State supplies of goods through an ECO with
aggregate turnover up to the threshold limit
The persons making supplies of goods through an ECO who is required
to collect TCS under section 52 and having an aggregate turnover in
the preceding financial year and in the current financial year not
exceeding the threshold limit in accordance with the provisions of
section 22(1), are exempted from obtaining registration, subject to the
following conditions, namely:
(i) such persons shall not make any inter-State supply of goods;
(ii) such persons shall not make supply of goods through ECO in
more than one State/Union territory;
(iii) such persons shall be required to have a PAN issued under the
Income-tax Act, 1961;
(iv) such persons shall, before making any supply of goods through
ECO, declare on the common portal:
a. their PAN
b. address of their place of business and
c. State/UT in which such persons seek to make such supply,
which shall be subjected to validation on the common portal;
(v) such persons have been granted an enrolment number on the
common portal on successful validation of the PAN declared
above;
(vi) such persons shall not be granted more than one enrolment
number in a State/UT;
(vii) no supply of goods shall be made by such persons through ECO
unless such persons have been granted an enrolment number on
the common portal; and

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 REGISTRATION 9.27

(viii) where such persons are subsequently granted registration under

section 25, the enrolment number shall cease to be valid from the
effective date of registration.
[Notification No. 34/2023 CT dated 31.07.2023]
Liability to register in respect of services provided by the commission agent
as per APMC Act for sale/ purchase of agricultural produce
CBIC 14 has clarified the issue as to whether the services provided by the commission
agent as per APMC Act for sale/ purchase of agricultural produce qualify as supply
under GST with the help of the following example. It further examines and clarifies
the registration requirements of such commission agents.
Mr. A sells agricultural produce by utilizing the services of Mr. B who is a
commission agent as per the Agricultural Produce Marketing Committee Act (APMC
Act) of the State 15. Mr. B identifies the buyers and sells the agricultural produce on
behalf of Mr. A for which he charges a commission from Mr. A.
In case where the invoice is issued directly by Mr. A to the buyer, the commission
agent (Mr. B) doesn’t fall under the category of agent covered under Schedule I.
However, in case where the invoice is issued by Mr. B to the buyer, Mr. B is an agent
as covered under Para 3 of Schedule I to the CGST Act. Hence, in such cases, the
services supplied by commission agent Mr. B on behalf of the principal without
consideration shall be deemed to be a supply – Concept of Deemed Supply under
Schedule-I has been discussed in detail in Chapter 2 – Supply under GST.
The registration requirements of the commission agents in such cases have been
examined and clarified as follows:
(i) As we have already seen, as per section 24, a person is liable for mandatory
registration if he makes taxable supply of goods or services or both on
behalf of other taxable persons.
Accordingly, a commission agent will be liable to get mandatorily registered
under this provision only when both the following conditions are satisfied:
(a) the principal should be a taxable person; and

14
Circular No. 57/31/2018 GST dated 04.09.2018
15
As per the APMC Act, the commission agent is a person who buys or sells the agricultural
produce on behalf of his principal, or facilitates buying and selling of agricultural produce on
behalf of his principal and receives, by way of remuneration, a commission or percentage upon
the amount involved in such transaction.

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 9.28 GOODS AND SERVICES TAX

(b) the supplies made by the commission agent should be taxable.

However, generally, a commission agent under APMC Act makes supplies on
behalf of an agriculturist who is not a taxable person if he supplies produce
out of cultivation of land 16 [as seen above].
Thus, a commission agent, who is making supplies on behalf of non-
taxable person [viz. agriculturist], is not liable for compulsory
registration under this provision.
(ii) Further, since the services provided by the commission agent for sale/
purchase of agricultural produce are exempt from GST 17, such commission
agents are not liable to be registered in accordance with provisions of
section 23(1)(a) [as discussed above].
(iii) However, where a commission agent is liable to pay tax under reverse charge,
such an agent will be required to get registered compulsorily (We have
already seen under previous heading that persons liable to pay tax under
reverse charge are required to obtain registration mandatorily).
The provisions of section 23 can be summarized in the following diagram:

Person engaged exclusively in the Person engaged exclusively in the

business of supplying goods/ services/ business of supplying goods/ services/
both not liable to tax both wholly exempt from tax
Persons not liable for
registration
Specified category of persons notified
Agriculturist to the extent of supply of
by the Government on GST Council
produce out of cultivation of land
recommendation

ILLUSTRATION 1
Examine, with reason, whether registration is required, under CGST Act, in the
following independent cases:
(i) Aadhav Computers of Gujarat is providing computer maintenance service.
Aggregate turnover of Aadhav Computers is ` 15 lakh which comprises both
inter-State and intra-State supply.

16
in terms of section 23(1)(a)
17
Notification No. 12/2017 CT (R) dated 28.06.2017 [Discussed in Chapter 5 – Exemptions
from GST in Module-1 of the Study material.]

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 REGISTRATION 9.29

(ii) Soft Wings of West Bengal, exclusively trading in garments, supplies its taxable
goods in various States of India from its outlet in West Bengal. Aggregate
turnover of Soft Wings is ` 35 lakh.
ANSWER
(i) Registration is compulsory for suppliers engaged in inter-State supply.
However, as per Notification No. 10/2017 IT dated 13.10.2017, threshold
exemption of ` 20 lakh [` 10 lakh in case of Special Category States of
Mizoram, Tripura, Manipur and Nagaland] is available in case of inter-State
supply of taxable services.
Therefore, Aadhav Computers (aggregate turnover ` 15 lakh) is not required
to obtain registration even though it is engaged in inter-State supply of
taxable services.
(ii) The threshold limit for registration in the State of West Bengal for the persons
engaged exclusively in supply of goods, is ` 40 lakh. However, registration is
compulsory if the supplier is engaged inter-State supply of goods irrespective
of the quantum of aggregate turnover. The threshold exemption is not
available in case of inter-State supply of taxable goods. Thus, Soft Wings is
required to obtain registration.
ILLUSTRATION 2
Examine whether the liability to register compulsorily under section 24 arises in each
of the independent cases mentioned below:

(1) Meenu, a supplier in Maharashtra, is exclusively engaged in supply of potatoes

produced out of cultivation of her own land, within Maharashtra and also
outside Maharashtra.

(2) Jinu Oils, Gujarat, is engaged in supplying machine oil as well as petrol. Further,
it provides intra-state services of refining of oil to customers. Total turnover of
supply of machine oil is ` 10 lakh, supply of petrol is ` 5 lakh and supply of
services is ` 6 lakh.
(3) Tilu is working as an agent, he is supplying taxable goods as an agent of Tiku
(who is registered taxable person) and its aggregate turnover does not exceed
the applicable threshold limit during the financial year. Invoices to customers
are issued in name of Tilu.

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 9.30 GOODS AND SERVICES TAX

ANSWER
(1) Section 24 provides that persons making any inter-State taxable supply of
goods are required to obtain registration compulsorily under GST laws
irrespective of the quantum of aggregate turnover.
However, as per section 23, an agriculturist, to the extent of supply of produce
out of cultivation of land, is not liable to registration.
Meenu is exclusively engaged in cultivation and supply of potatoes. Thus,
she is not liable to registration irrespective of the fact that she is engaged in
making inter-State supply of goods. Further, Meenu will not be liable to
registration, in the given case, even if her turnover exceeds the threshold
limit.

(2) Section 24 specifies the categories of persons who are required to be

mandatorily registered under GST irrespective of the quantum of their
aggregate turnover.
In the given case, Jinu Oils does not fall in any of the specified categories.
Therefore, it is not required to obtain registration compulsorily under GST.
However, as per section 22 read with Notification No. 10/2019 CT dated
07.03.2019, a supplier is liable to be registered in the State/Union territory
from where he makes a taxable supply of goods and/or services, if his
aggregate turnover in a financial year exceeds the threshold limit. The
threshold limit for a person making supply of both goods and services is
` 10 lakh for the States of Mizoram, Tripura, Manipur and Nagaland and
` 20 lakh for the rest of India. Thus, the applicable threshold limit for the State
of Gujarat is ` 20 lakh for supply of both goods and services. Further,
aggregate turnover includes exempted turnover of goods or services.
Accordingly, Jinu Oils is liable obtain registration since its aggregate turnover
[` 21 lakh (including turnover of exempt supply of petrol)] exceeds the
threshold limit of ` 20 lakh.
(3) Section 24 provides that persons who make taxable supply of goods and/or
services on behalf of other taxable persons whether as an agent or otherwise
are required to obtain registration compulsorily under GST laws irrespective
of the quantum of aggregate turnover.
Therefore, Tilu will be mandatorily required to obtain registration.

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 REGISTRATION 9.31

7. PROCEDURE FOR REGISTRATION [SECTIONS

25, 26 & 27]

STATUTORY PROVISIONS

Section 25 Procedure for registration

Sub-section Particulars
(1) Every person who is liable to be registered under section 22 or
section 24 shall apply for registration in every such State or Union
territory in which he is so liable within thirty days from the date
on which he becomes liable to registration, in such manner and
subject to such conditions as may be prescribed.
Provided that a casual taxable person or a non-resident taxable
person shall apply for registration at least five days prior to the
commencement of business.
Provided further that a person having a unit, as defined in the
Special Economic Zones Act, 2005, in a Special Economic Zone or
being a Special Economic Zone developer shall have to apply for
a separate registration, as distinct from his place of business
located outside the Special Economic Zone in the same State or
Union territory.
Explanation—Every person who makes a supply from the
territorial waters of India shall obtain registration in the coastal
State or Union territory where the nearest point of the appropriate
baseline is located.

(2) A person seeking registration under this Act shall be granted a

single registration in a State or Union territory.
Provided that a person having multiple places of business in a
State or Union territory may be granted a separate registration for
each such place of business, subject to such conditions as may be
prescribed.
(3) A person, though not liable to be registered under section 22 or
section 24 may get himself registered voluntarily, and all

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 9.32 GOODS AND SERVICES TAX

provisions of this Act, as are applicable to a registered person,

shall apply to such person.
(4) A person who has obtained or is required to obtain more than one
registration, whether in one State or Union territory or more than
one State or Union territory shall, in respect of each such
registration, be treated as distinct persons for the purposes of this
Act
(5) Where a person who has obtained or is required to obtain
registration in a State or Union territory in respect of an
establishment, has an establishment in another State or Union
territory, then such establishments shall be treated as
establishments of distinct persons for the purposes of this Act.
(6) Every person shall have a Permanent Account Number issued
under the Income- tax Act, 1961 in order to be eligible for grant
of registration.
Provided that a person required to deduct tax under section 51
may have, in lieu of a Permanent Account Number, a Tax
Deduction and Collection Account Number issued under the said
Act in order to be eligible for grant of registration.
(6A) Every registered person shall undergo authentication, or furnish
proof of possession of Aadhaar number, in such form and manner
and within such time as may be prescribed.
Provided that if an Aadhaar number is not assigned to the
registered person, such person shall be offered alternate and
viable means of identification in such manner as Government
may, on the recommendations of the Council, prescribe.
Provided further that in case of failure to undergo authentication
or furnish proof of possession of Aadhaar number or furnish
alternate and viable means of identification, registration allotted
to such person shall be deemed to be invalid and the other
provisions of this Act shall apply as if such person does not have
a registration.
(6B) On and from the date of notification, every individual shall, in
order to be eligible for grant of registration, undergo
authentication, or furnish proof of possession of Aadhaar number,
in such manner as the Government may, on the recommendations

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 REGISTRATION 9.33

of the Council, specify in the said notification.

Provided that if an Aadhaar number is not assigned to an
individual, such individual shall be offered alternate and viable
means of identification in such manner as the Government may,
on the recommendations of the Council, specify in the said
notification.
(6C) On and from the date of notification, every person, other than an
individual, shall, in order to be eligible for grant of registration,
undergo authentication, or furnish proof of possession of Aadhaar
number of the Karta, Managing Director, whole time Director,
such number of partners, Members of Managing Committee of
Association, Board of Trustees, authorised representative,
authorised signatory and such other class of persons, in such
manner, as the Government may, on the recommendation of the
Council, specify in the said notification.
Provided that where such person or class of persons have not been
assigned the Aadhaar Number, such person or class of persons
shall be offered alternate and viable means of identification in
such manner as the Government may, on the recommendations
of the Council, specify in the said notification.
(6D) The provisions of sub-section (6A) or sub-section (6B) or sub-
section (6C) shall not apply to such person or class of persons or
any State or Union territory or part thereof, as the Government
may, on the recommendations of the Council, specify by
notification.
Explanation—For the purposes of this section, the expression
“Aadhaar number” shall have the same meaning as assigned to it
in clause (a) of section 2 of the Aadhaar (Targeted Delivery of
Financial and Other Subsidies, Benefits and Services) Act, 2016
(7) Notwithstanding anything contained in sub-section (6), a non-
resident taxable person may be granted registration under sub-
section (1) on the basis of such other documents as may be
prescribed
(8) Where a person who is liable to be registered under this Act fails
to obtain registration, the proper officer may, without prejudice to
any action which may be taken under this Act or under any other

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 9.34 GOODS AND SERVICES TAX

law for the time being in force, proceed to register such person in
such manner as may be prescribed
(9) Notwithstanding anything contained in sub-section (1),––
(a) any specialised agency of the United Nations Organisation
or any Multilateral Financial Institution and Organisation
notified under the United Nations (Privileges and
Immunities) Act, 1947, Consulate or Embassy of foreign
countries; and
(b) any other person or class of persons, as may be notified by
the Commissioner,
shall be granted a Unique Identity Number in such manner and
for such purposes, including refund of taxes on the notified
supplies of goods or services or both received by them, as may be
prescribed.
(10) The registration or the Unique Identity Number shall be granted
or rejected after due verification in such manner and within such
period as may be prescribed.
(11) A certificate of registration shall be issued in such form and with
effect from such date as may be prescribed.
(12) A registration or a Unique Identity Number shall be deemed to
have been granted after the expiry of the period prescribed under
sub-section (10), if no deficiency has been communicated to the
applicant within that period.
Section 26 Deemed registration
(1) The grant of registration or the Unique Identity Number under the
State Goods and Services Tax Act or the Union Territory Goods and
Services Tax Act shall be deemed to be a grant of registration or
the Unique Identity Number under this Act subject to the condition
that the application for registration or the Unique Identity
Number has not been rejected under this Act within the time
specified in sub-section (10) of section 25.
(2) Notwithstanding anything contained in sub-section (10) of section
25, any rejection of application for registration or the Unique
Identity Number under the State Goods and Services Tax Act or

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 REGISTRATION 9.35

the Union Territory Goods and Services Tax Act shall be deemed
to be a rejection of application for registration under this Act.
Section 27 Special provisions relating to casual taxable person and
non-resident taxable person
(1) The certificate of registration issued to a casual taxable person or
a non- resident taxable person shall be valid for the period
specified in the application for registration or ninety days from the
effective date of registration, whichever is earlier and such person
shall make taxable supplies only after the issuance of the
certificate of registration.
Provided that the proper officer may, on sufficient cause being
shown by the said taxable person, extend the said period of ninety
days by a further period not exceeding ninety days.
(2) A casual taxable person or a non-resident taxable person shall, at
the time of submission of application for registration under sub-
section (1) of section 25, make an advance deposit of tax in an
amount equivalent to the estimated tax liability of such person for
the period for which the registration is sought.
Provided that where any extension of time is sought under
sub-section (1), such taxable person shall deposit an additional
amount of tax equivalent to the estimated tax liability of such
person for the period for which the extension is sought.
(3) The amount deposited under sub-section (2) shall be credited to
the electronic cash ledger of such person and shall be utilized in
the manner provided under section 49.

ANALYSIS
Procedure for registration is governed by section 25 read with relevant CGST Rules.
Relevant provisions of CGST Rules have been incorporated at the relevant places.
Further, special provisions have been provided for registration of casual taxable
person and non-resident taxable person under section 27. Concept of deemed
registration has been elaborated under section 26. Under GST, the application for
registration has to be submitted electronically at the GST Common Portal –
[Link], duly signed or verified.

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 9.36 GOODS AND SERVICES TAX

A large number of forms/formats relating to registration have been prescribed in

the CGST Rules. For every process in the registration chain such as application for
registration, acknowledgment, query, rejection, registration certificate, show cause
notice for cancellation, reply, cancellation, amendment, field visit report etc., there
are separate standard formats 18. This makes the process uniform all over the
country. The decision-making process has also been expedited. Strict time-lines
have been stipulated for completion of different stages of registration process.
(i) Where and by when to apply for registration? [Section 25(1)]

Particulars Where When

Person who is liable to in every such within 30 days from the

be registered under State/UT in which he date on which he
section 22 or section 24 is so liable becomes liable to
registration

A casual taxable person at least 5 days prior to

or a non-resident commencement of
taxable person business

Every person who in the coastal within 30 days from the

makes a supply from State/UT where the date on which he
the territorial waters of nearest point of the becomes liable to
India appropriate base registration
line is located.

(17) Sugam Services Ltd. is engaged in taxable supply of services

in Delhi. The turnover of Sugam Services Ltd. exceeded ` 20 lakh
on 1st November. It is liable to apply for registration by
1st December in Delhi.
(ii) State-wise registration [Section 25(2) read with rule 11]
(A) One registration per State
 Registration needs to be taken State-wise, i.e. there is no
centralized registration under GST. A business entity having its

18
Students are advised to go through various forms/formats relating to registration at
[Link] for knowledge purpose.

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 REGISTRATION 9.37

branches in multiple States will have to take separate State-wise

registration for its branches in different States.
 Further, within a State, an entity with different branches shall be
granted single registration wherein it can declare one place as
principal place of business (PPoB) and other branches as
additional places of business (APoB).
(B) Separate registration for different places of business within a
State/UT may be granted
 Although a taxpayer having multiple places of business in one
State is not mandatorily required to obtain separate registration
for each such place of business in the State, he has an option to
obtain independent registrations with respect to each such
separate place of business.
 However, separate registration for each place of business shall be
granted provided all separately registered places of business of
such person pay tax on supply of goods/services/both made to
another registered place of business, of such person and issue a
tax invoice/bill of supply, for such supply. Separate registration
application needs to be filed for each place of business.
 A registered person opting to obtain separate registration for a
place of business shall submit a separate application in
Form GST REG 01 in respect of such place of business.
(18) Meethalal & Sons - a supplier in Maharshtra - has three
branches in Mumbai, Pune and Mahabaleshwar. Mumbai and
Pune branches are engaged in supply of garments and
Mahabaleshwar branch engaged in supply of shoes.
It can obtain single registration for Mahrashtra declaring one of the
branches as PPoB and other two branches as APoB or it can obtain
separate GST registration for each of the three branches in Mumbai,
Pune and Mahabaleshwar as separate places of business.
In case Meethalal & Sons opts to have separate registrations for its all
three branches and Mumbai branch sends some garments [subject to
GST] for sale to Pune branch, Mumbai branch must raise a tax invoice
and pay tax on such transfer of garments to Pune branch.

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 9.38 GOODS AND SERVICES TAX

(C) Composition levy in case of separate registration for multiple

places of business within a State/UT
 If a person is paying tax for one of his places of business under
normal scheme, he cannot opt to pay tax under composition levy
for any other place of business.
 If one of the places of business [separately registered] of a
registered person becomes ineligible to pay tax under
composition levy, all other registered places of business of said
person would also become ineligible to pay tax under
composition levy.
 The provisions of rules 9 and 10 [Discussed in subsequent paras]
relating to verification and grant of registration shall mutatis
mutandis apply to an application submitted under this rule.
(iii) Voluntary registration [Section 25(3)]
A person who is not liable to be registered under section 22 or section 24
may get himself registered voluntarily. In case of voluntary registration, all
provisions of this Act, as are applicable to a registered person, shall apply to
voluntarily registered person. However, once a person obtains voluntary
registration, he has to pay tax even though his aggregate turnover does not
exceed ` 40 lakh/` 20 lakh/` 10 lakh, as the case may be.
Voluntary registration is usually obtained by businesses for ensuring seamless
flow of credit to their customers.
(iv) Distinct Persons/ establishments of distinct persons [Section 25(4) & (5)]
A person who has obtained/ is required to obtain more than one registration,
whether in one State/ Union territory or more than one State/Union territory
shall, in respect of each such registration, be treated as distinct persons.
Further, where a person who has obtained or is required to obtain registration
in a State or Union territory in respect of an establishment, has an
establishment in another State or Union territory, then such establishments
shall be treated as establishments of distinct persons. These concepts have
already been discussed in detail in Chapter 2– Supply under GST.

© The Institute of Chartered Accountants of India

 REGISTRATION 9.39

(v) PAN must for obtaining registration [Section 25(6) & (7)]
Permanent Account Number is mandatory to be eligible for grant of
registration.

🌟🌟 A Non-Resident Taxable Person (NRTP) may be granted registration on the

basis of other prescribed documents [Elaborated in subsequent paras].

(vi) Unique Identity Number (UIN) [Section 25(9) & (10) read with rule 17]

Any specialized agency of the United Nations

Organization or any Multilateral Financial institution
and organization as notified under the United Nations
(Privileges and Immunities) Act, 1947, consulate or
embassy of foreign countries and any other person
notified by the Commissioner, is required to obtain a
UIN from the GSTN portal.
This UIN is needed for claiming refund of taxes paid
on notified supplies of goods and/or services received
by them, and for such other purpose as may be
notified. UIN granted is a centralized UIN i.e. it shall
be applicable to the territory of India. A person
having UIN is not registered person and thus, is not
a taxable person.
The proper officer may, upon submission of an application in prescribed form
or after filling up the said form or after receiving a recommendation from the
Ministry of External Affairs, Government of India, assign a UIN to the said
person and issue a certificate in Form GST REG 06 within 3 working days
from the date of submission of application.
(vii) Suo-motu registration by the proper officer [Section 25(8) read with rule 16]
Where, pursuant to any survey, enquiry, inspection,
search or any other proceedings under the Act, the Temporary
proper officer finds that a person liable to registration registration
under the Act** has failed to apply for such registration,
such officer may register the said person on a temporary basis and issue an
order in prescribed form.

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 9.40 GOODS AND SERVICES TAX

**Such person shall either:

(i) submit an application for registration in prescribed form within 90 days
from the date of grant of temporary registration, or
(ii) file an appeal against such temporary registration.
In case (ii), if the Appellate Authority upholds the liability to registration,
application for registration shall be submitted within 30 days from the date
of issuance of such order of the Appellate Authority.
Provisions relating to verification and issue of registration certificate [as
contained in rules 9 and 10] [discussed in subsequent paras] shall, mutatis
mutandis, apply to such application submitted by the person granted
temporary registration. GSTIN thereafter granted shall be effective from the
date of order of proper officer granting temporary registration.
(viii) Procedure for registration [Section 25 read with rules 8, 9 & 10]
Provisions relating to procedure for application for registration, verification
of the application and approval & issue of registration certificate are
contained in the rules 8, 9 and 10 respectively. The same have to be read in
conjunction with section 25 provisions. The procedure for registration
prescribed under rules 8, 9 and 10 are also applicable to a person paying tax
under composition levy, every person seeking voluntary registration as well
as a casual taxable person.

A person who wants to obtain registration shall apply for the same in Form
GST REG 01. The application for registration in GST Form REG 01 is divided
into two parts – Part A and Part B.

Above procedure will not apply to:

 Non-resident taxable person (NRTP)
 A person required to deduct tax at source under section 51
 A person required to collect tax at source under section 52
 A person supplying OIDAR services from a place outside India to a
non-taxable online recipient referred to in section 14 of the IGST
Act.
 A person supplying online money gaming from a place outside
India to a person in India referred to in section 14A of the IGST Act.

© The Institute of Chartered Accountants of India

 REGISTRATION 9.41

Separate registration forms and procedure have been prescribed for

each of the aforesaid persons. Procedure relating to NRTP, TDS and TCS
has been discussed subsequently in this chapter, but procedure for
OIDAR services and online money gaming services provided from a place
outside India to a person in India have been covered at the Final level.

Facilitation centres
In order to cater to the needs of tax payers
who are not IT savvy, Facilitation centres have
been established which help the taxpayers in
submitting the application for registration,
amending the registration certificate,
submitting application for cancellation of
registration, revocation of cancellation of
registration, etc. Facilitation Centre shall be
responsible for the digitization and/or
uploading of the forms and documents.
Application for registration by Special Economic Zone (SEZ) [Second
proviso to section 25(1): A person having unit in SEZ/an SEZ developer will
have to make a separate application for registration as distinct from his place
of
SEZ is a geographically bound
zone where the economic laws
relating to export and import are
more liberal as compared to
other parts of the country. SEZ is
considered to be a place outside
India for all tax purposes.

business located outside SEZ in the same State/UT. Thus, there may be a case
where two units of a tax payer are located in same State/UT - one in SEZ and
another outside SEZ. In that case, separate registrations have to be obtained
for each of the two units as separate places of business.
(19) Suvarna Industries is engaged in manufacturing activities in
Uttar Pradesh. It has two manufacturing units in UP - one in SEZ
and another outside SEZ. Under GST, one registration per State is

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 9.42 GOODS AND SERVICES TAX

required. However, since in this case, one of the two units of Suvarna
Industries is located in SEZ, SEZ unit will have to compulsorily make a separate
application for registration as a place of business distinct from unit located
outside SEZ in the same State.
Procedure for registration has been depicted by way of a diagram below:

Procedure for registration

Part I

Every person liable to get registered and person seeking voluntary registration shall,
before applying for registration, declare his Permanent Account Number (PAN) and
State/UT in Part A of FORM GST REG-01 on GST Common Portal.

PAN is validated online by Common Portal from CBDT database and is also be verified
through separate OTPs sent to the PAN linked mobile number and e-mail address.

Temporary Reference Number (TRN) is generated and communicated to the applicant

on the validated mobile number and e-mail address.

Using TRN, applicant shall electronically submit application in Part B of

application form, along with specified documents at the Common Portal.
Part B of application contains the details, such as, constitution of business,
jurisdiction, option for composition, date of commencement of business,
reason to obtain registration, address of PPoB and nature of activity carried
out therein, details of APoB, details of bank account(s), details of authorized
signatory, aadhaar authentication, etc.

On receipt of such application, an acknowledgement in the prescribed form

shall be issued to the applicant electronically. A Casual Taxable
Person(CTP) applying for registration gets a TRN for making an advance
deposit of tax in his electronic cash ledger and an acknowledgement is
issued only after said deposit.*

Application shall be forwarded to the Proper Officer.

The procedure after receipt of application by the Proper Officer is depicted in Part II.

* Discussed in detail in subsequent paras.

© The Institute of Chartered Accountants of India

 Part-II
Proper Officer examines the application and where a person fails to undergo
accompanying documents. Aadhaar authentication/does not
opt for Aadhaar authentication

Proper Officer within 30 days where PO deems it fit to carry out

If same are issues notice from application site verification
No submission date
found in thereby where a person, who has
Yes order? seeking undergone Aadhaar
clarification**, authentication, is identified on
Yes
information or common portal, based on data
Registration within 7
Registration is documents analysis & risk parameters, to
granted within working days
granted within 30 from the carry out site verification
from application
7 working days of application applicant submission date

© The Institute of Chartered Accountants of India

days from the after verification of electronically Other cases
date of site & prescribed No
submission of documents If applicant has furnished the clarification**,
application information or documents within 7 working
without site where days’ time from receipt of notice?
where
verification applicant where a person, who has
PO (C)
fails to undergone Aadhaar
REGISTRATION

deem Yes
if applicant undergo authentication, is identified
s it fit If proper officer is satisfied with it? No
successfully Aadhaar on common portal, based
to
validates his authenticat on data analysis & risk
carry
aadhaar ion/ does parameters, to carry out site Yes
out Proper officer
authentication, not opt for verification Proper officer will grant registration
site may reject the
Aadhaar within 7 working days from the date
verific application for
(A) authentication of receipt of information/
ation
9.43

(B) reasons to be
(B) clarification/ documents
(B) recorded in
writing.
**Clarification includes modification/correction of particulars declared in the application for
registration other than PAN, State Mobile No. & E-mail address.
 9.44 GOODS AND SERVICES TAX

✮ Deemed Approval of Application

If the proper officer fails to take any action in the following cases within the
stipulated time, the application for grant of registration shall be deemed to
have been approved-

•within a period of 30 days from the date of

in cases where a person is
submission of the application
covered in above
(B)

•within a period of 7 working days from the

in case of a person covered in
date of submission of the application
above (A)

•within 7 working days from the date of

receipt of clarification, information or
in cases covered in (C) above
documents furnished by the applicant

To summarise:

 In case of successful authentication of Aadhaar and no SCN being

issued, registration will be deemed to be approved within 7
working days.

 If Aadhar authentication is not opted for/ aadhaar authentication

fails in validation/ PO deems it fit to carry out site verification and
no SCN is issued, registration will be deemed to be approved within
30 days by tax officer.

 Tax Officer can issue SCN within 7 working days, for grant of
registration, in cases of successful Aadhar authentication.

 In cases when taxpayer do not opt to provide Aadhaar/when

Aadhar authentication fails/ PO deems it fit to carry out site
verification, he can issue SCN upto 30 days. In both cases,
applicants can submit their reply within 7 working days from issue
of SCN.

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 REGISTRATION 9.45

AADHAAR AUTHENTICATION
[Section 25(6A), (6B), (6C) & (6D) read with rules 8, 9, 10B and 25]

As seen above, there’s a simplified registration procedure under GST.

However, this easy registration procedure was unduly misused by fly-by-night
operators. Thus, in an endeavor to curb/check such operators and to increase
compliance, aadhaar e-KYC based registration was introduced under the GST
law. Aadhaar authentication is mandatory for the new applicants (whether an
individual applicant or an applicant other than individual) in order to be
eligible for grant of registration. Aadhaar Authentication is required to be
complied with, by the persons applying for GST registration as normal
taxpayer/ composition/ casual taxable person/ Input Service Distributor (ISD)/
SEZ Developer/ SEZ Unit etc, in Form GST REG 01.
Existing registrants (those who are already registered under GST) are also
required to undergo aadhaar authentication.
How aadhaar authentication is done?
New registrants
While filing the application for registration, the applicant gets an option as
to whether he wants to opt for Aadhaar authentication or not. If he opts ‘Yes’
for Aadhaar authentication, GST system sends "authentication link" on the
mobile numbers and email ids (mentioned in the registration application) of
promotor/partner, and primary authorized signatory which are selected by
the applicant 19.
On clicking the verification link, a window for Aadhaar authentication opens
where they enter the Aadhaar Number and the OTP received by them on the
mobile number and email id linked with Aadhaar.
Once Aadhaar authentication has been successfully validated, his application
will be deemed to be approved within 7 working days and the registration

19
While opting for Aadhaar authentication, the applicant needs to select atleast 1 Primary
Authorized Signatory and 1 Promoter/ Partner/Karta/Director/Member for authentication
purposes.

© The Institute of Chartered Accountants of India

 9.46 GOODS AND SERVICES TAX

application submitted by him will not be marked for mandatory site visit,
unless the tax official raises a show cause notice within stipulated time.
However, in case the applicant does not opt for Aadhaar authentication while
applying for registration or where his Aadhar authentication fails in validation,
the applicant who has undergone aadhaar authentication is identified for site
visit based on data analysis and risk parameters or proper officer deems it fit to
carry out site visit, registration application will not be deemed approved within
7 working days and it will be marked for mandatory site visit and approval
thereafter, by the tax official. Registration application will get deemed approved
after 30 calendar days, if tax official doesn't take any action.
If tax official raises SCN within 30 calendar days, then applicant has 7 working
days to reply to it. Tax official can take further action on that reply within 7
working days. If tax official doesn't take any action after receipt of applicant’s
reply within next 7 working days, his application will get deemed approved.
Existing registrants
All the regular taxpayers and composition taxpayer are required to get
Aadhaar authenticated for existing GST registration. An existing taxpayer can
get himself Aadhaar authenticated on GST portal using either Aadhaar
authentication link or uploading E-KYC documents 20.
Let us go through the aadhaar authentication process in detail:
A. Persons required to undergo aadhaar authentication
As per section 25(6A), (6B) and (6C), following persons are required to
undergo aadhaar authentication:
(1) New applicant [Rule 8(4A), (4B) and (5)]
Every (i) individual applicant or (ii) an applicant, other than an
individual, shall undergo authentication/furnish proof of
possession of Aadhaar number, in the manner prescribed in
rule 8 21.

20
It is not mandatory for every authorized signatory, promoter or partner to get Aadhaar
authenticated for an existing GST registration. The Aadhaar authentication will be needed only
for 1 Primary Authorized Signatory and 1 Promoter/ Partner/ Karta/ Director/ Member.
21
Notification No. 18/2020 CT dated 23.03.2020

© The Institute of Chartered Accountants of India

 REGISTRATION 9.47

(i) Where an applicant opts for authentication of Aadhaar

number: Rule 8(4A) provides that where an applicant opts
for authentication of Aadhaar number, he shall, while
submitting an application for registration, undergo
authentication of Aadhaar number. Said authentication
is required to be eligible for grant of registration.
Date of submission of the application in such cases shall
be earlier of:
(a) the date of authentication of the Aadhaar number,
or
(b) 15 days from the submission of the application in
Part B of Form GST REG-01.
Whose aadhaar numbers shall be verified?
In case applicant is an individual, he shall undergo
authentication of his own aadhaar number.
In case applicant is other than individual, the
authentication will be of aadhaar number of the Karta,
Managing Director, whole time Director, such number of
partners, Members of Managing Committee of
Association, Board of Trustees, authorised representative,
authorised signatory and such other notified class of
persons [authorised signatory of all types, Managing and
Authorised partners of a partnership firm and Karta of a
Hindu Undivided Family, have been so notified 22].(E)
Risk-based biometric-based aadhaar authentication of
registration applicants 23
An applicant who has opted for authentication of Aadhaar
number and is identified on the common portal, based on
data analysis and risk parameters, shall be followed by

22
Notification No. 19/2020 CT dated 23.03.2020
23
First proviso to rule 8(4A)

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 9.48 GOODS AND SERVICES TAX

biometric-based Aadhaar authentication and taking

photograph:
(i) of the applicant where the applicant is an individual or
(ii) of notified individuals (mentioned as (E) above) in
relation to the applicant where the applicant is not
an individual,
along with the verification of the original copy of the
documents uploaded with the application form at one of
the notified Facilitation Centres.

The application shall be deemed to be complete only after

completion of the process laid down hereunder.
An acknowledgement shall be issued to the applicant only
after completion of biometric-based authentication.
(ii) Where an applicant does not opt for authentication of
Aadhaar number 24: The application of a person who has
not opted for authentication of Aadhaar number, shall be
followed by taking photograph:
• of the applicant where the applicant is an individual or
• of notified individuals (mentioned as (E) above) in
relation to the applicant where the applicant is not an
individual,
along with the verification of the original copy of the
documents uploaded with the application form at one of
the notified Facilitation Centers.
The application shall be deemed to be complete only after
completion of the process laid down hereunder.

24
Second proviso to rule 8(4A)

© The Institute of Chartered Accountants of India

 REGISTRATION 9.49

(2) Persons already registered

Every registered person shall undergo authentication/furnish

proof of possession of Aadhaar number, in prescribed form and
manner and within the prescribed time.

The manner in which aadhaar authentication needs to be done by

a registered person is prescribed as under:-
A registered person, who has been issued a certificate of
registration under GST, shall undergo authentication of the
Aadhaar number of:-
 Proprietor, in the case of proprietorship firm,
 Any partner, in the case of a partnership firm,
 Karta, in the case of a Hindu undivided family,
 Managing director or any whole-time director, in the case
of a company,
 Any of the Members of the Managing Committee of an
Association of persons or body of individuals or a Society,
or
 Trustee in the Board of Trustees, in the case of a Trust;
and of the Authorized Signatory,
in order to be eligible for the following purposes:
 for filing of application for revocation of cancellation of
registration [Rule 23]
 for filing of refund application in Form RFD-01 [Rule 89]
 for refund of the IGST paid on goods exported out of India
[Rule 96].
B. Where Aadhaar number is not assigned
(1) In case of new applicant
If an aadhaar number is not assigned to a new applicant – either
(i) an individual or (ii) person/class of persons (other than

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 9.50 GOODS AND SERVICES TAX

individual), such individual/person/class of persons shall be

offered alternate and viable means of identification in the manner
specified in rule 9 25.
Proviso to rule 9(1) provides that where:
(i) a person fails to undergo authentication of aadhaar number
or does not opt for authentication of Aadhaar number, or

(ii) a person, who has undergone authentication of Aadhaar

number, is identified on the common portal, based on data
analysis and risk parameters for carrying out physical
verification of places of business
(iii) the proper officer (PO), with the approval of an officer
authorised by the Commissioner not below the rank of
Assistant Commissioner, deems it fit to carry out physical
verification of places of business
the registration shall be granted within 30 days of submission of
application only after physical verification of the principal place of
business, in the prescribed manner (specified in rule 25 discussed
subsequently) and verification of such documents as the proper
officer may deem fit.
Where the application submitted under rule 8 is found to be
deficient, either in terms of any information or any document
required to be furnished under the said rule, or where the proper
officer requires any clarification with regard to any information
provided in the application or documents furnished therewith, he
may issue a notice to the applicant electronically in within a period
of 7 working days from the date of submission of the application
and the applicant shall furnish such clarification, information or
documents electronically within a period of 7 working days from
the date of the receipt of such notice [Rule 9(2)].

25
Provisos to section 25(6B) and 25(6C) read with Notification No.s 18 and 19/2020 CT both
dated 23.03.2020

© The Institute of Chartered Accountants of India

 REGISTRATION 9.51

However, in such cases, i.e. where:

(i) a person fails to undergo Aadhaar authentication/does not opt

for Aadhaar authentication or
(ii) a person, who has undergone authentication of Aadhaar
number, is identified on the common portal, based on data
analysis and risk parameters, for carrying out physical
verification of places of business; or
(iii) PO deems it fit to carry out site verification,
the notice (in prescribed form) seeking clarifications/ information/
documents from the applicant may be issued by the proper officer
not later than 30 days from the submission of the application for
registration [Proviso to rule 9(2)].
2. In case of already registered persons [Rule 10B]
If an Aadhaar number is not assigned to an existing registered
person, such person shall be offered alternate and viable means
of identification in the prescribed manner 26.
Such manner has been prescribed as follows:
If Aadhaar number has not been assigned to the person required
to undergo authentication of the Aadhaar number, such person
shall furnish the following identification documents, namely: –
(a) his/ her Aadhaar Enrolment ID slip; and
(b) (i) Bank passbook with photograph; or

(ii) Voter identity card issued by the Election Commission

of India; or
(iii) Passport; or

(iv) Driving license issued by the Licensing Authority

26
First proviso to section 25(6A)

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 9.52 GOODS AND SERVICES TAX

However, once Aadhaar number is allotted to such person, he

shall undergo the authentication of Aadhaar number within a
period of 30 days of the allotment of the Aadhaar number.
In case of failure to undergo aadhaar authentication/furnish proof
of possession of Aadhaar number/furnish alternate and viable
means of identification, registration allotted to such person shall
be deemed to be invalid and the other provisions of this Act shall
apply as if such person does not have a registration 27.
C. Persons/class of persons exempt from aadhaar authentication

Section 25(6D) stipulates that above provisions shall not apply to such
person or class of persons or any State or Union territory or part thereof,
as may be notified.

Following persons have been notified in this regard 28:

 A person who is not a citizen of India
 Department or establishment of State Government or Central
Government
 Local authority
 Statutory body

 Public Sector Undertaking

 A person applying for Unique Identity Number under section 25(9)
Furnishing of bank account details [Rule 10A]

As seen in the diagram outlining the procedure for registration, while filing
the application for registration on GST portal, in Part B of the application
form, a person is required to furnish the details of his bank account. Rule 10A
relaxes this requirement to a limited extent. In pursuance to the same, the
registered person is allowed to furnish information within a period of 30 days
from the date of grant of registration, or before furnishing the details of
outward supplies of goods or services or both under section 37 in GSTR-1 or

27
Second proviso to section 25(6A)
28
Notification No. 03/2021 CT dated 23.02.2021

© The Institute of Chartered Accountants of India

 REGISTRATION 9.53

using IFF, whichever is earlier, furnish information with respect to details of

bank account on the common portal.
In short, a taxpayer has an option to give his bank account details after
obtaining registration, within 30 days from the date of grant of
registration or the due date of furnishing details of outward supplies,
whichever is earlier.
However, this relaxation is not available for those who have been granted
registration as TDS deductor/ TCS collector under rule 12 29 or suo-motu
registration under rule 16. They are mandatorily required to furnish the bank
account details at the time of filing the application for registration.
Physical verification of business premises in certain cases [Rule 25]
(1) Where the proper officer is satisfied that the physical verification
of the place of business of a person is required AFTER the grant of
registration: he may get such verification of the place of business done
and the verification report along with the
other documents, including photographs,
shall be uploaded in prescribed form on the
common portal within a period of 15 working
days following the date of such verification.
(2) Where the physical verification of the
place of business of a person is required
BEFORE the grant of registration in the
circumstances specified in the proviso to rule
9(1) [as given in (B earlier]: the proper officer
shall get such verification of the place of business
done and the verification report along with the
other documents, including photographs, shall be uploaded in
prescribed form on the common portal at least 5 working days prior to
the completion of the time period specified in the said proviso.

The provisions relating to TDS and TCS have been discussed in detail in Chapter 14 in this
29

Module of the Study Material.

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 9.54 GOODS AND SERVICES TAX

Issuance of registration certificate [Rule 10]

Where the application for grant of registration has been approved, a
certificate of registration duly signed or verified through EVC by the proper
officer in Form GST REG-06 showing the PPoB and APoB is made available
to the applicant on the Common Portal and a Goods and Services Tax
Identification Number (hereinafter referred to as “GSTIN”) i.e. the GST
registration no. is communicated to applicant, within 3 days after the grant
of registration.
GSTIN format
State Code PAN Entity Check sum
Code character

Display of registration certificate and GSTIN on the name board [Rule 18]
Every registered person shall display his registration certificate in a prominent
location at his PPoB and at every APoB. Further, his GSTIN also has to be displayed
on the name board exhibited at the entry of his PPoB and at every APoB.
(ix) Effective date of registration [Rule 10]

Where an applicant submits Effective date of registration

application for registration
Within 30 days from the date Date on which person becomes
the person becomes liable to liable to registration
registration
After 30 days from the date the Date of grant of registration
person becomes liable to
registration

(20) Sugam Services Ltd. is engaged in taxable supply of services

in Madhya Pradesh. The turnover of Sugam Services Ltd. exceeded
` 20 lakh on 1st November. It is liable to get registered by 1st
December [30 days] in the State of Madhya Pradesh. It applies for registration
on 28th November and is granted registration certificate on 5th December.
The effective date of registration of Sugam Services Ltd. is 1st November.

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 REGISTRATION 9.55

(21) In above example, if Sugam Services Ltd. applies for

registration on 3rd December and is granted registration certificate
on 10th December. The effective date of registration of Sugam
Services Ltd. is 10th December.
ILLUSTRATION 3
Determine the effective date of registration under CGST Act in respect of the
following cases with proper explanation:
(i) The aggregate turnover of Varun Industries of Mumbai has exceeded
` 40 lakh on 1stAugust. Varun Industries manufactures LED TVs in
Mumbai and sells them in Pune. It submits the application for
registration on 20thAugust. Registration certificate granted on 25thAugust.
(ii) Sweta InfoTech Services is the provider of internet services in Pune. Its
aggregate turnover exceeds ` 20 lakh on 25th September. It submits the
application for registration on 27thOctober. Registration certificate is
granted on 5thNovember.
ANSWER
As per section 22 read with Notification No. 10/2019 CT dated 07.03.2019, a
supplier is liable to be registered in the State/Union territory from where he
makes a taxable supply of goods and/or services, if his aggregate turnover in
a financial year exceeds the threshold limit. The threshold limit for a person
making exclusive intra-State taxable supplies of goods is as under:-
(a) ` 10 lakh for the States of Mizoram, Tripura, Manipur and Nagaland.
(b) ` 20 lakh for the States of States of Arunachal Pradesh, Meghalaya,
Puducherry, Sikkim, Telangana and Uttarakhand.

(c) ` 40 lakh for rest of India. However, the higher threshold limit of
` 40 lakh is not available to persons engaged in making supplies of ice
cream and other edible ice, whether or not containing cocoa, pan
masala and tobacco and manufactured tobacco substitutes,
The threshold limit for a person making exclusive taxable supply of services
or supply of both goods and services is as under:-

(a) ` 10 lakh for the States of Mizoram, Tripura, Manipur and Nagaland.

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 9.56 GOODS AND SERVICES TAX

(b) ` 20 lakh for the rest of India.

As per rule 10, where a person submits the application for registration within
30 days of becoming liable for registration, the effective date of registration
is the date on which the person becomes liable to registration; otherwise it is
the date of grant of registration.
In the light of the above provisions, in the given cases, the applicable turnover
limit for registration will be ` 40 lakh and ` 20 lakh in case (i) and (ii)
respectively.
(i) Since Varun Industries applied for registration within 30 days of
becoming liable to registration, the effective date of registration is 1st
August.
(ii) Since Sweta InfoTech Services applied for registration after the expiry
of 30 days from the date of becoming liable to registration, the effective
date of registration is 5th November.
(x) Special provisions for grant of registration in case of Non-Resident
Taxable Person (NRTP) and Casual Taxable Person (CTP) [Sections 25 &
27 read with rules 13 & 15]
(A) Meaning of casual taxable person and non-resident taxable person
Before going into nuances of the registration provisions of CTP and
NRTP, let us first understand the meaning of casual taxable person and
non-resident taxable person:
Casual Taxable Person
There may be case where a person has a registered business in some
State in India, but wants to effect supplies from some other State in
which he does not have any fixed place of business. Such person needs
to register in the State from where he seeks to supply as a ‘casual
taxable person’.

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 REGISTRATION 9.57

The CGST Act defines a casual taxable person as a person who

occasionally undertakes transactions
involving supply of goods or services or
both in the course or furtherance of
business, whether as principal, agent or in
any other capacity, in a State/UT where he
has no fixed place of business [Section
2(20)]. Further, he cannot exercise the
option to pay tax under composition levy.
(22) Krishnadev & Co., engaged in supplying taxable goods,
is registered in Rajasthan. It wishes to participate in a 5 days’
business exhibition being held in Delhi. However, it does not
have a fixed place of business in Delhi. In this case, Krishnadev & Co.
has to obtain registration as a casual taxable person in Delhi.
Non-Resident Taxable Person
A person who is a foreigner and occasionally wants to effect taxable
supplies from any State in India needs
GST registration for the same. Such
person needs to register in the State
from where he seeks to supply as a non-
resident taxable person. CGST Act
defines non-resident taxable person
as any person who occasionally
undertakes transactions involving
supply of goods or services or both,
whether as principal or agent or in any
other capacity, but who has no fixed place of business or residence
in India [Section 2(77)]. He cannot exercise the option to pay tax under
composition levy.
Based on the aforesaid definitions, following points merit consideration:
 A CTP does not have a fixed place of business in the State/UT
where he undertakes supply though he might be registered with
regard to his fixed place of business in some other State/UT, while

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 9.58 GOODS AND SERVICES TAX

a NRTP does not have fixed place of business/residence in India

at all.
 A CTP has to undertake transactions in the course or furtherance
of business whereas the business test is absent in the definition
of NRTP.
(B) Special registration provisions of casual taxable person and
non-resident taxable person
GST law prescribes special procedure for registration, as also for
extension of the operation period of such casual or non-resident
taxable persons. They have to apply for registration at least 5 days in
advance before making any supply. Also, registration is granted to them
or period of operation is extended, only after they make advance
deposit of the estimated tax liability. The special registration
procedure pertaining to CTP and NRTP is as follows:
(A) Both CTP 30 and NRTP have to compulsorily get registered under
GST irrespective of the threshold limit, at least 5 days prior to
commencement of business.
(B) As per section 25(6), every person must have a PAN to be eligible
for registration. Since NRTP will generally not have a PAN of India,
he may be granted registration on the basis of other prescribed
documents.

Thus, a NRTP has to submit a self-attested copy of his valid

passport along with the application duly signed or verified
through electronic verification code by his authorized signatory
who is an Indian Resident having valid PAN. However, in case of
a business entity incorporated or established outside India, the
application for registration shall be submitted along with its tax
identification number or unique number on the basis of which the
entity is identified by the Government of that country or its PAN,
if available.

30
Subject to exemption from registration under Notification No. 56/2018 CT dated 23.10.2018

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 REGISTRATION 9.59

Application will be submitted by NRTP in a different prescribed form

whereas CTP will submit the application for registration in the normal
form for application for registration i.e. Form GST REG 01 and his
registration of CTP will be a PAN based registration.
(C) Period of validity of registration certificate granted to CTP/NRTP
Registration Certificate granted to
CTP/NRTP will be valid for:
(i) Period specified in the registration CTP and NRTP will
application, or make taxable
supplies only after
(ii) 90 days from the effective date of
the issuance of the
registration [can be extended certificate of
further by a period not exceeding registration.
90 days by making an application
before the end of the validity of
registration granted to him**]
whichever is earlier.

Provisions relating to verification of application and grant of

registration [under rules 9 and 10] will apply mutatis mutandis, to an
application for registration filed by NRTP.
(D) Advance deposit of tax
At the time of submitting the registration application, CTP/NRTP are
required to make an advance deposit of tax in an amount equivalent
to the estimated tax liability of such person for the period for which the
registration is sought.
Further, CTP/NRTP will get a Temporary Reference Number (TRN) for
making an advance deposit of tax which shall be credited to his
electronic cash ledger. An acknowledgement of receipt of application
for registration is issued only after said deposit.
**Where extension of time is sought, CTP/NRTP will deposit an
additional amount of tax equivalent to the estimated tax liability of
such person for the period for which the extension is sought.

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 9.60 GOODS AND SERVICES TAX

(xi) Deemed registration [Section 26]

Registration under GST is not tax specific, which means that there is single
registration for all the taxes i.e. CGST, SGST/UTGST, IGST and cess.
Grant of registration/UIN under any SGST Act/ UTGST Act is deemed to be
registration/UIN granted under CGST Act provided application for
registration has not been rejected under CGST Act.
Further, rejection of application for registration/UIN under SGST Act/UTGST
Act is deemed to be rejection of application for registration under CGST Act.
(xii) Special provisions for grant of registration in case of persons required
to deduct tax at source under section 51 or to collect tax at source under
section 52 [Rule 12]
Application for registration has to be submitted by such persons in a different
prescribed form at GST Common Portal. They would be granted registration
within 3 working days from the date of submission of application after due
verification.
Where, on a request made in writing by a person to whom a registration has
been granted under rule 12(2) or upon an enquiry or pursuant to any other
proceeding under the CGST Act, the proper officer is satisfied that a person
to whom a certificate of registration has been issued is no longer liable to
deduct tax at source under section 51 or collect tax at source under section
52, the said officer may cancel the registration issued and such cancellation
shall be communicated to the said person electronically.

8. AMENDMENT OF REGISTRATION [SECTION 28]

A registered person or UIN holder may need to make some changes/ amendments
in the registration application. There are two categories of details in registration
application – core and non-core fields.
Core fields are name of the business, (legal name) if there is no change in PAN,
addition / deletion of stakeholders 31, principal place of business (other than change
in State) or additional place of business (other than change in State).

31
Refer diagram given on Page No. 9.62

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 REGISTRATION 9.61

All other fields are non-core fields like name of day to day functionaries, e-mail
ids, mobile numbers, etc.
In case the change is in core information in the registration application, the
taxable person will apply for amendment within 15 days of the event necessitating
the change. The proper officer, then, will approve the amendment within next 15
days.
For other changes – non-core information, no approval of the proper officer is
required, and the amendment can be affected by the taxable person on his own on
the common portal.
The provisions relating to amendment of registration are contained in section 28
read with rule 19.
The significant aspects of the same are discussed hereunder:
 Where there is any change in the particulars furnished in registration
application/UIN application, registered person shall submit an application
in prescribed manner, either at the time of obtaining registration or
Unique Identity Number or as amended from time to time, within 15 days
of such change, along with documents relating to such change at the
Common Portal.
 In case of amendment of core fields of information, the proper officer
may, on the basis of information furnished or as ascertained by him,
approve or reject amendments in the registration particulars in the
prescribed manner. Such amendment shall take effect from the date of
occurrence of event warranting such amendment.
 However, where change relates to non-core fields of information,
registration certificate shall stand amended upon submission of the
application for amendment on the Common Portal.
 The proper officer shall not reject the application for amendment in the
registration particulars without giving the person an opportunity of being
heard.
 Any rejection or approval of amendments under the SGST/UTGST Act shall
be deemed to be a rejection or approval under the CGST Act.

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 9.62 GOODS AND SERVICES TAX

 Any particular of the application for registration shall not stand amended
with effect from a date earlier than date of submission of application for
amendment on common portal except with order of Commissioner for
reasons to be recorded in writing and subject to conditions specified by
Commissioner in the said order.
 Application for amendment of registration cannot be filed for change in
PAN because GST registration is PAN-based. One needs to make fresh
application for registration in case there is change in PAN. Thus, where a
change in the constitution of any business results in change of PAN of a
registered person, the said person shall apply for fresh registration.
 Similarly, application for amendment of registration form cannot be filled
if there is change in place of business from one State to the other because
GST registrations are State-specific. If one wishes to relocate his business
to another State, he must voluntarily cancel his current registration and
apply for a fresh registration in the State he is relocating his business.

Core fields of information

Permission of proper officer required if change

relates to core fields of information

and such change does not warrant cancellation of registration under

section 29

Addition/deletion/retirement of
stakeholders (partners or directors,
Legal name Address of Karta, Managing Committee, Board
of business PPoB/APoB of Trustees, Chief Executive Officer
or equivalent, responsible for day to
day affairs of the business)

Change of these two particulars shall be applicable for all registrations

of a registered person obtained under provisions of this Chapter on same
PAN

Mobile no./e-mail address of authorised signatory can be amended only after online
verification through GST Portal.

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 REGISTRATION 9.63

Submission of application
Core areas
within 15 days of change

Registered Person/
UIN holder GST
Common Portal

Non-core areas

Amendment carried out on GST

Common Portal
Proper Officer (PO)

Permission to be
granted within next 15
Registration certificate days No
Is PO of the opinion
amended
that amendment is
unwarranted/
Yes documents furnished
PO will serve a SCN why
are incomplete/
application for amendment within 15 working days of incorrect?
should not be rejected? receipt of application

If registered person replies to

No the notice within 7 working
days?
Yes

No
Yes
If reply is
satisfactory?
Application for amendment
shall be rejected.
Within 7 working days of receipt of supply

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 9.64 GOODS AND SERVICES TAX

If the proper officer fails to take any action,-

(a) within a period of 15 working days from the date of submission of the
application, or
(b) within a period of 7 working days from the date of the receipt of the reply to
the show cause notice,
the certificate of registration shall stand amended to the extent applied for and the
amended certificate shall be made available to the registered person on the
common portal.
(23) Varun Enterprises, a sole proprietorship firm, is engaged in supply
of electrical goods in Delhi. The firm is registered under GST. Varun is
the proprietor of the firm. He wishes to expand his business and his
friend – Arun - approaches him to provide additional capital for his business if he
is made a partner in Varun’s business.
Varun agrees and changes the constitution of his business and forms a partnership
firm – Varun Arun & Co. Since the change in constitution of business from sole
proprietorship firm to partnership firm results in change in PAN of the registered
person, the partnership firm has to apply for fresh registration. The reason for the
same is that GSTIN is PAN based. Any change in PAN would warrant a new
registration.

9. CANCELLATION OR SUSPENSION OF
REGISTRATION AND REVOCATION OF
CANCELLATION [SECTIONS 29 & 30]

STATUTORY PROVISIONS

Section 29 Particulars

Sub-section Cancellation or suspension of registration

(1) The proper officer may, either on his own motion or on an application
filed by the registered person or by his legal heirs, in case of death of
such person, cancel the registration, in such manner and within such

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period as may be prescribed, having regard to the circumstances

where:

(a) the business has been discontinued, transferred fully for any
reason including death of the proprietor, amalgamated with
other legal entity, demerged or otherwise disposed of

(b) there is any change in the constitution of the business

(c) the taxable person is no longer liable to be registered under

section 22 or section 24 or intends to optout of the registration
voluntarily made under sub-section (3) of section 25.

Provided that during pendency of the proceedings relating to

cancellation of registration filed by the registered person, the
registration may be suspended for such period and in such manner
as may be prescribed.

(2) The proper officer may cancel the registration of a person from such
date, including any retrospective date, as he may deem fit, where,––

(a) a registered person has contravened such provisions of the Act

or the rules made thereunder as may be prescribed

(b) a person paying tax under section 10 has not furnished the
return for a financial year beyond three months from the due
date of furnishing the said return

(c) any registered person, other than a person specified in clause

(b), has not furnished returns for such continuous tax period as
may be prescribed

(d) any person who has taken voluntary registration under sub-
section (3) of section 25 has not commenced business within six
months from the date of registration

(e) registration has been obtained by means of fraud, wilful

misstatement or suppression of facts

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 9.66 GOODS AND SERVICES TAX

Provided that the proper officer shall not cancel the registration
without giving the person an opportunity of being heard.

Provided further that during pendency of the proceedings relating to

cancellation of registration, the proper officer may suspend the
registration for such period and in such manner as may be prescribed.

(3) The cancellation of registration under this section shall not affect the
liability of the person to pay tax and other dues under this Act or to
discharge any obligation under this Act or the rules made thereunder
for any period prior to the date of cancellation whether or not such
tax and other dues are determined before or after the date of
cancellation.

(4) The cancellation of registration under the State Goods and Services
Tax Act or the Union Territory Goods and Services Tax Act, as the case
may be, shall be deemed to be a cancellation of registration under
this Act.

(5) Every registered person whose registration is cancelled shall pay an

amount, by way of debit in the electronic credit ledger or electronic
cash ledger, equivalent to the credit of input tax in respect of inputs
held in stock and inputs contained in semi-finished or finished goods
held in stock or capital goods or plant and machinery on the day
immediately preceding the date of such cancellation or the output
tax payable on such goods, whichever is higher, calculated in such
manner as may be prescribed.
Provided that in case of capital goods or plant and machinery, the
taxable person shall pay an amount equal to the input tax credit
taken on the said capital goods or plant and machinery, reduced by
such percentage points as may be prescribed or the tax on the
transaction value of such capital goods or plant and machinery under
section 15, whichever is higher.

(6) The amount payable under sub-section (5) shall be calculated in such
manner as may be prescribed.

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 REGISTRATION 9.67

Section 30 Revocation of cancellation of registration

(1) Subject to such conditions as may be prescribed, any registered

person, whose registration is cancelled by the proper officer on his
own motion, may apply to such officer for revocation of cancellation
of the registration such manner, within such time and subject to such
conditions and restrictions, as may be prescribed.

(2) The proper officer may, in such manner and within such period as may
be prescribed, by order, either revoke cancellation of the registration
or reject the application.
Provided that the application for revocation of cancellation of
registration shall not be rejected unless the applicant has been given
an opportunity of being heard.
Provided further that such revocation of cancellation of
registration shall be subject to such conditions and restrictions,
as may be prescribed.

(3) The revocation of cancellation of registration under the State Goods

and Services Tax Act or the Union Territory Goods and Services Tax
Act, as the case may be, shall be deemed to be a revocation of
cancellation of registration under this Act.

ANALYSIS
The provisions relating to cancellation of registration and its revocation are
contained in sections 29 & 30 respectively read with rules 20 to 23. The registration
granted under GST can be cancelled for specified reasons. The cancellation can
either be initiated by the Department on their own motion or the registered person
can apply for cancellation of their registration.

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 9.68 GOODS AND SERVICES TAX

Where the For example, in case

Voluntary registered of death of registered
Cancellation of registration

cancellation by person no more person, the legal heirs

registered person requires the can apply for
registration cancellation

Where the For example, when

Proper Officer the registrant is not
considers the doing business from
Suo-motu the registered place
registration of a
cancellation by the of business or if he
person liable for
Department issues tax invoice
cancellation in without making the
view of certain supply of goods or
defaults services.

(i) Circumstances where registration is liable to be cancelled [Section

29(1) & (2)]
A. Circumstances when the registration can be cancelled either suo
motu by proper officer or on an application of the registered
person or his legal heirs (in case death of such person)

Cancellation by the registered person on its own or by the Department

--Business discontinued
--Transferred fully for Taxable person who is
any reason including no longer liable to be
death of the proprietor Change in the registered under
--Amalgamated with constitution of the section 22 or section 24
other legal entity business or who intends to
optout of the voluntary
--Demerged or
registration.
--Otherwise disposed of

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 REGISTRATION 9.69

B. Circumstances when the proper officer can cancel registration on

his own
In the following cases, registration can be cancelled by the proper
officer from such date, including any retrospective date, as he may
deem fit, after giving an opportuniy of being heard:

A registered person has

contravened the prescribed
provisions (Refer below **)

Registration was A registered person

obtained by means of has not filed returns
fraud, wilful Proper for specified
misstatement or officer can continuous tax
suppression of facts cancel periods [Refer
registration clauses (h) & (i)
on his own if below]

Voluntarily registered person Composition tax payer has

has not commenced the not furnished return for a
business within 6 months from FY beyond 3 months from
the date of registration due date of furnishing
return

**Prescribed contraventions which make a registered person liable to

cancellation of registration [Rule 21]: The registered person-
(a) does not conduct any business from the declared place of
business, or
(b) issues invoice/bill without supply of goods/services in violation of
the provisions of this Act, or the rules made thereunder.

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 9.70 GOODS AND SERVICES TAX

(c) violates the provisions of section 171. Section 171 contains

provisions relating to anti-profeetering measure 32.
(d) violates the provision of rule 10A (discussed earlier in this chapter).
(e) avails input tax credit in violation of the provisions of section 16 33
of the CGST Act or the rules made thereunder.
(f) furnishes the details of outward supplies in Form GSTR-1, as
amended in FORM GSTR-1A if any, under section 37 for one or
more tax periods which is in excess of the outward supplies
declared by him in his valid return under section 39 for the said
tax periods.
(g) violates the provision of rule 86B 34.
(ga) violates the provisions of third or fourth proviso to rule 23(1).

(h) required to file return under section 39(1) for each month or part
thereof (i.e. monthly return filer), has not furnished returns for
a continuous period of 6 months.

(i) required to file return under proviso to section 39(1) for each
quarter or part thereof (Quarterly return under QRMP scheme),
has not furnished returns for a continuous period of 2 tax
periods.
C. Suspension of registration [First proviso to section 29(1) and
second proviso to section 29(2) read with rule 21A]

Once a registered person has applied for

cancellation of registration or the proper
officer seeks to cancel his registration, the
proper officer may suspend his registration
during pendency of the proceedings relating
to cancellation of registration. In this way, a taxpayer is freed from the

32
Anti-profeetering measure shall be discussed at Final Level.
33
Provisions of section 16 have been discussed in detail in Chapter 8 – Input Tax Credit.
34
Provisions of rule 86B have been discussed in detail in Chapter 8 – Input tax credit.

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 REGISTRATION 9.71

routine compliances, including filing returns, under GST law during the
pendency of the proceedings related to cancellation of registration.
The period and manner of suspension of registration is as follows:
1. Where registered person has applied for cancellation of
registration: Where a registered person has applied for
cancellation of registration, the registration shall be deemed to
be suspended from:
(a) the date of submission of the application
or
(b) the date from which the cancellation is sought,
whichever is later,
pending the completion of proceedings for cancellation of
registration.

2. Where cancellation of the registration has been initiated by

the Department on its own motion: Where the proper officer
has reasons to believe that the registration of a person is liable to
be cancelled, he may suspend the registration of such person with
effect from a date to be determined by him, pending the
completion of the proceedings for cancellation of registration.

Where,-
(a) a comparison of the returns furnished by a registered person
under section 39 with the details of outward supplies furnished in
GSTR-1, as amended in GSTR-1A if any, or the details of inward
supplies derived based on the details of outward supplies
furnished by his suppliers in their GSTR-1, as amended in GSTR-
1A if any, of the previous tax period, if any, or such other analysis,
as may be carried out on the recommendations of the Council,
show that there are significant differences or anomalies indicating
contravention of the provisions of the Act or the rules made
thereunder, leading to cancellation of registration of the said
person, or

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 9.72 GOODS AND SERVICES TAX

(b) there is a contravention of the provisions of rule 10A [furnishing

of bank account details] by the registered person, the registration
of such person shall be suspended and the said person shall be
intimated in the prescribed form, electronically, on the common
portal, or by sending a communication to his e-mail address
provided at the time of registration or as amended from time to
time, highlighting the said differences, anomalies or non-
compliances and asking him to explain, within a period of 30 days,
as to why his registration shall not be cancelled.
In cases where the cancellation is initiated by the Department on
its own and registration of a person has been suspended, such
person shall not be granted any refund under section 54 35, during
the period of suspension of his registration.

3. A registered person, whose registration has been suspended as

above:
 shall not make any taxable supply** during the period of
suspension and
 shall not be required to furnish any return under section 39.
**The expression “shall not make any taxable supply” shall
mean that the registered person shall not issue a tax invoice and,
accordingly, not charge tax on supplies made by him during the
period of suspension.
4. The suspension of registration shall be deemed to be revoked
upon completion of the cancellation proceedings by the proper
officer. Such revocation shall be effective from the date on which
the suspension had come into effect.
The suspension of registration may be revoked by the proper
officer, anytime during the pendency of the proceedings for
cancellation, if he deems fit.

35
Section 54 contains provisions relating to refund of GST. The same shall be discussed at the
Final level.

© The Institute of Chartered Accountants of India

 REGISTRATION 9.73

5. Further, the suspension of registration shall be deemed to be

revoked upon furnishing of all the pending GST returns, where
GST registration was suspended due to non-filing of GST return
for a financial year beyond 3 months from the due date of
furnishing the said return by a composition taxpayer or returns
for such continuous tax period as may be prescribed by registered
persons (other than composition taxpayer) subject to the
condition that the registration has not been cancelled by the
proper officer under rule 22.
6. Further also, where the registration has been suspended under
sub-rule (2A) for contravention of provisions of rule 10A
[furnishing of bank account details] and the registration has not
already been cancelled by the proper officer under rule 22, the
suspension of registration shall be deemed to be revoked upon
compliance with the provisions of rule 10A.
7. Where any order having the effect of revocation of suspension of
registration has been passed, the provisions of section 31(3)(a)
[revised tax invoices] and section 40 [first return] in respect of the
supplies made during the period of suspension and the procedure
specified therein shall apply.
(ii) Procedure for cancellation of registration [Rules 20 and 22]
(a) Voluntary cancellation by registered person

Application
 A registered person seeking cancellation of registration 36 shall
electronically submit the application for cancellation of registration in
prescribed form within 30 days of occurrence of the event warranting
cancellation.
 He is required to furnish in the application the details of inputs held in
stock or inputs contained in semi-finished/finished goods held in stock
and of capital goods held in stock on the date from which
cancellation of registration is sought, liability thereon, details of the

36
Section 29(1)

© The Institute of Chartered Accountants of India

 9.74 GOODS AND SERVICES TAX

payment, if any, made against such liability and may furnish relevant
documents thereof.
Order
 Where a person who has submitted an application for cancellation of
his registration is no longer liable to be registered, proper officer shall
issue the order of cancellation of registration within 30 days from the
date of submission of application for cancellation.
(b) Suo-motu cancellation by the Department
 Where the proper officer cancels the registration suo-motu, he shall not
cancel the same without giving a show cause notice and without giving
a reasonable opportunity of being heard, to the registered person. The
reply to such show cause notice (SCN) has to be submitted within 7 days
of service of notice.
 If reply to SCN is satisfactory, proper officer shall drop the proceedings
and pass an order in prescribed form. However, where the person
instead of replying to the SCN served for failure to furnish returns for a
continuous period of 6 months or 2 tax periods, as the case may be
(return for a F.Y. beyond 3 months from due date of furnishing the said
return in case of composition scheme supplier) 37 furnishes all the
pending returns and makes full payment of the tax dues along with
applicable interest and late fee, the proper officer shall drop the
proceedings and pass an order.
Where registration of a person is liable to be cancelled, proper officer
shall issue the order of cancellation of registration within 30 days from
the date of reply to SCN.
(c) Effective date of cancellation
 The cancellation of registration shall be effective from a date to be
determined by the proper officer and mentioned in the cancellation
order. The taxable person will be directed in the said order to pay

37
viz. contravention of the provisions contained in section 29(2)(b)/(c) read with clauses (h) & (i)
of rule 21

© The Institute of Chartered Accountants of India

 REGISTRATION 9.75

arrears of any tax, interest or penalty including the amount liable to be

paid under section 29(5).
(iii) Amount payable on cancellation of registration [Section 29(5) & (6)]
A registered person whose registration is cancelled will have to debit the
electronic credit or cash ledger by an amount equivalent to:
(i) Input tax credit (ITC) in respect of:
 stock of inputs and inputs contained in semi-finished/finished
goods’ stock or
 capital goods or plant and machinery on the day immediately
preceding the date of cancellation, or
(ii) the output tax payable on such goods
whichever is higher, calculated in such manner as may be prescribed.
However, in case of capital goods or plant and machinery, the taxable
person shall pay an amount equal to the input tax credit taken on the said
capital goods or plant and machinery, reduced by such percentage points as
may be prescribed or the tax on the transaction value of such capital goods
or plant and machinery under section 15, whichever is higher.
The manner of determination of amount of credit to be reversed is prescribed
under rule 44. On conjoint reading of section 29(5) and rule 44, it can be
inferred as follows:
Amount of credit to be reversed in respect of INPUTS:

ITC in respect of inputs ITC on inputs computed

calculated in proportionately on the basis of
accordance with rule corresponding invoices** on
which credit had been availed on
whichever
44 of the CGST Rules* is higher
such inputs.

Output tax payable on such goods

* Discussed in detail in Chapter-8: Input Tax Credit in this Module of Study Material

**If tax invoices are not available, the ITC to be reversed will be based on the
prevailing market price (MP) of such goods on the date of cancellation.

© The Institute of Chartered Accountants of India

 9.76 GOODS AND SERVICES TAX

 Amount of credit to be reversed in respect of CAPITAL GOODS OR

PLANT & MACHINERY:

ITC in respect of ITC involved in the

capital goods or remaining useful life in
months of the capital
plant & machinery
goods computed on
calculated in
pro-rata basis, taking whichever is
accordance with the useful life as
rule 44 higher
5 years

Tax on the transaction value of such capital

goods or plant and machinery under section 15

(24) Capital goods have been in use for 4 years, 6 month and 15
days. The useful remaining life in months = 5 months ignoring a
part of the month.
ITC taken on such capital goods = C
ITC attributable to remaining useful life = C x 5/60
(iv) Other points about cancellation
 A person to whom a UIN has been granted under rule 17 cannot apply
for cancellation of registration [Rule 20]
 The cancellation of registration will not affect liability of registered
person to pay tax and other dues under the Act for any period prior to
the date of cancellation 38 [Section 29(3)].
(25) The proper officer cancelled the registration of Naman
Associates on 11th October. The tax dues of Naman
Associates for July-September quarter (determined by the
proper officer on 16th December) are ` 50,000. The cancellation of
registration of Naman Associates shall have no effect on his liability of
tax dues of ` 50,000 even though the tax dues are determined after the
cancellation of registration.

38
whether or not such tax and other dues are determined before or after the date of
cancellation.

© The Institute of Chartered Accountants of India

 REGISTRATION 9.77

 The cancellation of registration under either SGST Act/UTGST Act shall

be deemed to be a cancellation of registration under CGST Act [Section
29(4)].
 Once registration is cancelled by the tax authority, the taxpayer will be
intimated about the same via SMS and email. Order for cancellation of
registration will be issued and intimated to the primary authorized
signatory by email and SMS.
 Taxpayer would not be allowed by the Common portal to file return for
the period after date of cancellation mentioned in the cancellation
order. However, he can submit returns of the earlier period (i.e. for the
period before date of cancellation mentioned in the cancellation order
for which registration was active).
(v) Revocation of cancellation of registration [Section 30 read with rule 23]
(A) Procedure for revocation of cancellation
 Where the registration of a person is cancelled suo-motu by the
proper officer, such registered person, subject to the provisions
of rule 10B, may apply for revocation of the cancellation to such
proper officer, within a period of 90 days** from the date of the
service of the order of cancellation of registration.
**Said period of 90 days may, on sufficient cause being shown and
for reasons to be recorded in writing, be extended by the
Commissioner or an officer authorised by him in this behalf, not
below the rank of Additional Commissioner/Joint Commissioner,
as the case may be, for a further period not exceeding 180 days.
 Thus, a registered person, whose registration is cancelled by the
proper officer on his own motion, may subject to provisions of
rule 10B submit an application for revocation of cancellation of
registration, in prescribed form, to such proper officer, within a
period of 90 days from the date of the service of the order of
cancellation of registration at the common portal, either directly
or through a Facilitation Centre notified by the Commissioner.
 If the proper officer is satisfied that there are sufficient grounds
for revocation of cancellation, he may revoke the cancellation of

© The Institute of Chartered Accountants of India

 9.78 GOODS AND SERVICES TAX

registration, by an order within 30 days of receipt of application

and communicate the same to applicant.
 Otherwise, he may reject the revocation application. However,
before rejecting the application, he has to first issue SCN to the
applicant who shall furnish the clarification within 7 working days
of service of SCN. The proper officer shall dipose the application
(accept/reject the same) within 30 days of receipt of clarification.
(B) Where registration was cancelled for failure of registered person to
furnish returns
Where registration was cancelled for failure of registered person to furnish
returns, before applying for revocation, the person has to make good the
defaults, i.e. the person needs to file such returns and pay any amount due
as tax along with any amount payable towards interest, penalty and late
fee in respect of the said returns. However, the registration may have been
cancelled by the proper officer either from the date of order of cancellation
of registration or from a retrospective date.
(1) Where the registration has been cancelled with effect from
the date of order of cancellation of registration
As we have already seen that the common portal does not allow
furnishing of returns for the period after the effective date of
cancellation, but returns for the earlier period (i.e. for the period
before date of cancellation mentioned in the cancellation order)
can be furnished after cancellation.
Where the registration is cancelled with effect from the date of
order of cancellation of registration, person applying for
revocation of cancellation has to furnish all returns due till the
date of such cancellation before the application for revocation can
be filed and has to pay any amount due as tax, in terms of such
returns along with any amount payable towards interest, penalties
or late fee payable in respect of the said returns. However, since
the portal does not allow to furnish returns for the period after
the date of cancellation of registration, all returns due for the
period from the date of order of cancellation till the date of order
of revocation of cancellation of registration have to be furnished
within a period of 30 days from the date of the order of
revocation.

© The Institute of Chartered Accountants of India

 REGISTRATION 9.79

(26) The registration of Naman Associates was cancelled

by the proper officer by an order dated
1st June for its failure to furnish returns. The registration
was cancelled with effect from 1st June itself. It applied for
revocation of cancellation of registration and the order for
revocation of cancellation of Naman Associates is 31st July. In this
case, Naman Associates shall be required to furnish all the returns
for the period from 1st June to 31st July within a period of 30 days
from 31st July, i.e. by 30th August.

Returns for this period to be Returns for this period to be filed

filed before applying for within 30 days of the order of
revocation of cancellation revocation of cancellation
returns not furnished

Date of order of
Date from which

cancellation of

Date of order of

cancellation of
registration

revocation of

registration
Effective date
of cancellation
of registration

(2) Where the registration has been cancelled with retrospective

effect
Where the registration has been cancelled with retrospective effect,
it is not possible to furnish the returns before filing the application
for revocation of cancellation of registration. In that case, the
application for revocation of cancellation of registration is allowed
to be filed, subject to the condition that all returns relating to the
period from the effective date of cancellation of registration till the
date of order of revocation of cancellation of registration shall be
filed within a period of 30 days from the date of order of such
revocation of cancellation of registration.

© The Institute of Chartered Accountants of India

 9.80 GOODS AND SERVICES TAX

(27) The registration of Naman Associates was cancelled

by the proper officer by an order dated 1st June for its
failure to furnish returns. The registration was cancelled
with effect from 1st January itself. It applied for revocation of
cancellation of registration and the order for revocation of
cancellation of Naman Associates is passed on 31st July. In this case,
Naman Associates shall be required to furnish all the returns for the
period from 1st January to 31st July within a period of 30 days from
31st July, i.e. by 30th August.
Returns for this period to be filed within 30 days of the order of
revocation of cancellation
Date from which

Date of order of

Date of order of
cancellation of
returns not

cancellation of
furnished

revocation of
registration

registration
Effective date of
cancellation of
registration

Points to be noted

UIN Holders (i.e. UN Bodies, Embassies and Other Notified Persons),

GST Practitioner cannot apply for revocation of cancelled registration.

In case the registration is cancelled on the request of the taxpayer or

his legal heir, one cannot apply for revocation of cancelled registration.

The revocation of cancellation of registration under the SGST Act/

UTGST Act, as the case may be, shall be deemed to be a revocation of
cancellation of registration under CGST Act

© The Institute of Chartered Accountants of India

 REGISTRATION 9.81

LET US RECAPITULATE

Nature of registration

The registration in GST is PAN based and State specific.

One registration per State/UT.

However, a business entity having separate places of business in a State

may obtain separate registration for each of its places of business .

GST identification number called “GSTIN” - a 15-digit number and a

certificate of registration incorporating therein this GSTIN is made
available to the applicant on the GSTN common portal.

Registration under GST is not tax specific, i.e. single registration for all the
taxes i.e. CGST, SGST/UTGST, IGST and cesses.

Persons liable to registration

•Threshold limit elaborated separately in the diagram

Those who exceed threshold
below.
limit

In case of transfer of business •Transferee liable to be registered from the date of

on account of succession, etc. succession of business

In case of amalgamation/ •Transferee liable to be registered from the date on

demerger by an order of High which Registrar of Companies issues incorporation
Court etc. certificate giving effect to order of High Court etc.

Taxable Exempt Inter State Aggregate

Exports
Supplies supplies supplies Turnover

Aggregate Turnover will be computed on All-India basis for same PAN

© The Institute of Chartered Accountants of India

 9.82 GOODS AND SERVICES TAX

Applicable threshold limit

States with threshold limit of ` 10 •Manipur, Mizoram, Nagaland and Tripura

lakh for supplier of goods and/or
services

States/UTs with threshold limit of •Arunachal Pradesh, Meghalaya, Sikkim,

` 20 lakh for supplier of goods Uttarakhand, Puducherry and Telangana
and/or services

States/UTs with threshold limit of

` 20 lakh for supplier of services/ •Jammu and Kashmir, Assam, Himachal
both goods and services and ` 40 Pradesh, All other States
lakh for supplier of goods (Intra-
State)

Compulsory registration in certain cases

Casual taxable person

who does not have a A person receiving
Persons making any
fixed place of business supplies on which tax is
inter-State taxable
in the State or Union payable by recipient on
supply
Territory from where he reverse charge basis
wants to make supply

Those e-commerce
Non-resident taxable
operators who are Persons who are
persons who do not
notified as liable for tax required to deduct tax
have a fixed place of
payment under section under section 51 (TDS)
business in India
9(5)

A person who supplies Suppliers other than

Every e-commerce
on behalf of some other notified under section
operator who is
taxable person (i.e. an 9(5) who supply
required to collect tax at
Agent of some through an e-commerce
source
Principal) operator

Person/ class of persons

notified by the Central/
State Government

© The Institute of Chartered Accountants of India

 REGISTRATION 9.83

Persons not liable for registration

Person engaged
Persons making only
exclusively in Agriculturist limited
reverse charge
supplying goods/ to supply of produce
supplies except
services/ both not out of cultivation of
supplier of metal
liable to tax/ wholly land
scrap
exempt from tax

Casual Taxable
Persons making inter-
Persons making inter-
Persons making inter- State taxable supplies
State taxable supplies
State supplies of of notified handicraft
of notified handicraft
taxable services up to goods and notified
goods and notified
` 20 lakh** hand-made goods up
hand-made goods up
to ` 20 lakh**
to ` 20 lakh**

Persons making intra-State

Persons making supplies of
supplies of goods through an
services through an ECO
ECO with aggregate turnover
[other than supplies
not exceeding threshold limit
specified under section
and not making supply in more
9(5)] with aggregate
than one State/UT, with one
turnover up to ` 20 lakh**
enrolment no.
**` 10 lakh in case of Special Category States of Mizoram, Tripura, Manipur & Nagaland

Where and by when to apply for registration?

Person who is liable A casual taxable A person who makes

to be registered person or a non- a supply from the
under section 22 or resident taxable territorial waters of
section 24 person India
•in every such •in the coastal
•in every such
State/UT in which he State/UT where the
State/UT in which he
is so liable nearest point of the
is so liable
•within 30 days from appropriate base line
•at least 5 days prior
the date on which he is located.
to the
becomes liable to •within 30 days from
commencement of
registration the date on which he
business
becomes liable to
registration

© The Institute of Chartered Accountants of India

 9.84 GOODS AND SERVICES TAX

Voluntary Registration and UIN

•Person not liable to be registered under

Voluntary sections 22/24 may get himself registered
Registration voluntarily.

•In respect of supplies to some notified

Unique agencies of United Nations organisation,
Identification multinational financial institutions and
Number (UIN) other organisations, a UIN is issued.

Effective date of registration

Application submitted
within 30 days of the •Effective date is the date on which the
applicant becoming person becomes liable to registration
liable to registration

Application submitted
after 30 days of the •Effective date is date of grant of
applicant becoming registration
liable to registration

Deemed registration

Deemed registration

Grant of registration/UIN under any SGST Rejection of application for

Act/ UTGST Act is deemed to be registration/UIN under SGST Act/UTGST
registration/UIN granted under CGST Act Act is deemed to be rejection of
provided application for registration has application for registration under CGST
not been rejected under CGST Act. Act.

© The Institute of Chartered Accountants of India

 REGISTRATION 9.85

Procedure for registration has been depicted by way of a diagram below:

Procedure for registration

Part I

Every person liable to get registered and person seeking voluntary registration shall,
before applying for registration, declare his Permanent Account Number (PAN) and
State/UT in Part A of FORM GST REG-01 on GST Common Portal.

PAN is validated online by Common Portal from CBDT database and is also be verified
through separate OTPs sent to the PAN linked mobile number and e-mail address.

Temporary Reference Number (TRN) is generated and communicated to the applicant

on the validated mobile number and e-mail address.

Using TRN, applicant shall electronically submit application in Part B of

application form, along with specified documents at the Common Portal.
Part B of application contains the details, such as, constitution of business,
jurisdiction, option for composition, date of commencement of business,
reason to obtain registration, address of PPoB and nature of activity carried
out therein, details of APoB, details of bank account(s), details of authorized
signatory, aadhaar authentication, etc.

On receipt of such application, an acknowledgement in the prescribed form shall

be issued to the applicant electronically. A Casual Taxable Person (CTP) applying
for registration gets a TRN for making an advance deposit of tax in his electronic
cash ledger and an acknowledgement is issued only after said deposit.*

Application shall be forwarded to the Proper Officer.

The procedure after receipt of application by the Proper Officer is depicted in

Part II.

* Discussed in detail in subsequent paras.

© The Institute of Chartered Accountants of India

 Part-II
Proper Officer examines the application and where a person fails to undergo
accompanying documents. Aadhaar authentication/does not
opt for Aadhaar authentication

Proper Officer within 30 days where PO deems it fit to carry out

If same are issues notice from application site verification
found in No submission date
thereby
9.86

Yes order? seeking where a person, who has undergone

Aadhaar authentication, is identified
clarification**,
Yes on common portal, based on data
information or analysis & risk parameters, to carry
within 7
Registration Registration is documents out site verification
working days
granted within granted within 30 from the from application
7 working days days of application applicant submission date

© The Institute of Chartered Accountants of India

after verification of electronically Other cases
from the date
of submission site & prescribed No
documents If applicant has furnished the clarification**,
of application
information or documents within 7 working
without site
days’ time from receipt of notice?
verification where where
applicant where a person, who has (C)
PO Yes
fails to undergone Aadhaar
if applicant deems
undergo authentication, is If proper officer is satisfied with it? No
successfully it fit to
Aadhaar identified on common
validates his carry
authenticat portal, based on data
aadhaar out Yes
GOODS AND SERVICES TAX

ion/ does analysis & risk parameters, Proper officer

authentication, site Proper officer will grant registration
not opt for to carry out site may reject the
verifica within 7 working days from the date
Aadhaar verification application for
(A) tion of receipt of information/
authentication (B) reasons to be
clarification/ documents
(B) recorded in
(B)
writing.

**Clarification includes modification/correction of particulars declared in the application for

registration other than PAN, State Mobile No. & E-mail address.
 REGISTRATION 9.87

Special procedure for registration of CTP and NRTP

Casual Taxable Person Non-resident Taxable Person

A Casual taxable person is one

who has a registered business in
some State in India, but wants to A Non-Resident taxable
effect supplies from some other person is one who is a
State in which he is not having any foreigner and occasionally
fixed place of business. wants to effect taxable
supplies from any State in
Such person needs to register in India, and for that he needs
the State from where he seeks to GST registration.
supply as a Casual taxable person.

Casual Taxable Person Non-resident taxable person

GST law prescribes special procedure for registration, as also for extension of the
operation period of such Casual or Non-Resident taxable persons.

They have to apply for registration at least 5 days in advance before making any
supply.

Registration is granted to them or period of operation is extended only after

they make advance deposit of the estimated tax liability.

Registration is granted to them for the period specified in the registration

application or 90 days from the effective date of registration.

© The Institute of Chartered Accountants of India

 9.88 GOODS AND SERVICES TAX

Amendment of Registration

Except for the changes in some core information in the registration application,
a taxable person shall be able to make amendments without requiring any
specific approval from the tax authority.

In case there is change in core fields of information, the taxable person will
apply for amendment within 15 days of the event necessitating the change.
The Proper Officer, then, will approve the amendment within the next 15 days.

For changes in non-core fields, no approval of the Proper Officer is required,

and the amendment can be affected by the taxable person on his own on the
common portal.

Cancellation or suspension of registration and revocation of cancellation of

registration

A registered person has

Registration --Business Registration contravened the prescribed
can be discontinued/ can be provisions
cancelled Transferred/ cancelled
either by Amalgamated with by the
proper A registered person has not filed
other legal entity/ proper
officer or on returns for continuous 6 months
Demerged or officer on
an or 2 tax periods (return for a F.Y.
Otherwise disposed his own
application beyond 3 months from due date
of of furnishing the said return for
of the
registered composition supplier)
person
Change in the Voluntarily registered person has
constitution of the not commenced the business
business within 6 months from the date of
registration
Taxable person no
longer liable to be Registration was obtained by
registered or intends means of fraud, wilful
to opt out of misstatement or suppression of
voluntary registration facts

Once a registered person has applied for cancellation of registration or the proper officer seeks to cancel
his registration, proper officer may suspend his registration during pendency of proceedings relating to
cancellation of registration filed by such registered person.

© The Institute of Chartered Accountants of India

 REGISTRATION 9.89

Procedure for cancellation

Where the registered person Where the proper officer cancels

applies for cancellation the registration

PO shall issue a SCN to the registered person

Registered person seeking cancellation
who has to reply to said notice within 7 days.
shall apply for the same within 30 days of
occurrence of the event warranting
cancellation, in prescribed form, Proceedings shall be Cancellation
furnishing the details of inputs held in dropped order shall
stock or inputs contained in semi- be issued
finished/finished goods held in stock and within 30
of capital goods held in stock on the date If reply to Where instead days of reply
from which cancellation of registration is SCN is of replying to to SCN
sought, liability thereon, payment, if any satisfactory SCN, person where
furnishes all registration
made & relevant documents.
pending is liable to
returns & be cancelled
makes full
Proper officer (PO) shall issue the
payment of tax
order of cancellation within 30 days of
along with
submission of application for the interest & late
same. fee.

Revocation of cancellation
In case where registration is cancelled suo-motu by the proper officer, the taxable person can
apply within 90 days (extendible by 180 days by Commissioner or officer authorised not below
the rank of Additional/Joint Commissioner) of service of cancellation order, requesting the officer
for revoking the cancellation ordered by him.
However, before so applying, the person has to make good the defaults (by filing all pending
returns, making payment of all dues and so) for which the registration was cancelled by the
officer.
If satisfied, the proper officer will revoke the cancellation earlier ordered by him.
However, if the officer concludes to reject the request for revocation of cancellation, he will first
observe the principle of natural justice by way of issuing notice to the person and hearing him
on the issue.
However, there shall be deemed revocation of cancellation upon furnishing of pending GST
returns subject to the condition that the registration has not been cancelled by the proper
officer under rule 22.

Revocation of cancellation of registration shall be subject to such conditions and

restrictions, as may be prescribed.

© The Institute of Chartered Accountants of India

 9.90 GOODS AND SERVICES TAX

TEST YOUR KNOWLEDGE

1. Determine the effective date of registration in following cases:

(a) The aggregate turnover of Dhampur Footwear Industries of Delhi has
exceeded the applicable threshold limit of ` 40 lakh on 1st September. It
submits the application for registration on 20th September. Registration
certificate is granted to it on 25th September.
(b) Mehta Teleservices is an architect in Lucknow. Its aggregate turnover
exceeds ` 20 lakh on 25th October. It submits the application for
registration on 27th November. Registration certificate is granted to it on
5th December.
2. In order to be eligible for grant of registration, a person must have a Permanent
Account Number issued under the Income- tax Act, 1961. State one exception to it.
3. State which of the following suppliers are liable to be registered:
(a) Agents supplying taxable goods on behalf of some other taxable person
and such agent’s aggregate turnover does not exceed the applicable
threshold limit during the financial year.
Note: Invoices are issued to customers in the name of agent.
(b) An agriculturist who is engaged exclusively in supply of produce out of
cultivation of land and its aggregate turnover exceeds the applicable
threshold limit during the financial year.
4. Pure Oils, Delhi has supplied machine oil and high-speed diesel in the month
of April as per the details given in table below. Pure Oils is not yet registered.

Sl. No. Particulars Amount (`)*

(i) Supply of machine oil in Delhi 15,00,000

(ii) Supply of high speed diesel in Delhi 10,00,000

(iii) Supply of machine oil made in Punjab by Pure 10,00,000

Oils from its branch located in Punjab
*excluding GST
Determine whether Pure Oils is liable for registration.

© The Institute of Chartered Accountants of India

 REGISTRATION 9.91

5. What will be your answer if in question 4 above, in [Link]. (ii), Pure Oils supplies
the high speed diesel in Delhi in the capacity of an agent of Mixed Oils Ltd.,
(non-registered), where invoices to customers are issued in name of Pure Oils?
6. Examine whether the supplier of goods is liable to get registered in the following
independent cases:-
(i) Raghav of Assam is exclusively engaged in intra-State taxable supply of
readymade garments. His turnover in the current financial year (FY) from
Assam showroom is ` 33 lakh. He has another showroom in Tripura with
a turnover of ` 11 lakh in the current FY.
(ii) Pulkit of Panjim, Goa is exclusively engaged in intra-State taxable supply
of shoes. His aggregate turnover in the current financial year is ` 22 lakh.
(iii) Harshit of Himachal Pradesh is exclusively engaged in intra-State supply
of pan masala. His aggregate turnover in the current financial year is
` 24 lakh.
7. Examine whether the supplier is liable to get registered in the following
independent cases:-
(i) Ankit of Assam is exclusively engaged in intra-State supply of taxable
services. His aggregate turnover in the current financial year is
` 25 lakh.
(ii) Sanchit of Assam is engaged in intra-State supply of both taxable goods
and services. His aggregate turnover in the current financial year is
` 30 lakh.
8. What are the advantages of taking registration in GST?
9. Can a person without GST registration collect GST and claim ITC?
10. If a person is making taxable supplies from different States, with the same PAN
number, can he operate with a single registration?
11. Can a person having multiple places of business in a State obtain separate
registrations for each place of business?
12. Is there a provision for a person to get himself voluntarily registered though he
may not be liable to pay GST?

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 9.92 GOODS AND SERVICES TAX

13. Can the Department, through the proper officer, suo-moto proceed to register
a person under GST?
14. Whether the registration granted to any person is permanent?
15. Is it necessary for the UN bodies to get registration under GST?
16. What is the responsibility of the taxable person making supplies to UN bodies?
17 What is the validity period of the registration certificate issued to a casual
taxable person and non-resident taxable person?
18. What happens when the registration is obtained by means of willful mis-
statement, fraud or suppression of facts?

19 Is there an option to take centralized registration for services under GST Law?
20. What could be the liabilities (in so far as registration is concerned) on transfer
of a business?
21. At the time of registration, will the assessee have to declare all his places of
business?
22. Does cancellation of registration impose any tax obligations on the person
whose registration is so cancelled?

ANSWERS

1. (a) Every supplier becomes liable to registration if his turnover exceeds the
applicable threshold limit [` 40 lakh in this case] in a finacial year
[Section 22 read with Notification No. 10/2019 CT dated 07.03.2019].
Since in the given case, the turnover of Dhampur Industries exceeded
` 40 lakh on 1st September, it becomes liable to registration on said
date.
Further, since the application for registration has been submitted within
30 days from such date, the registration shall be effective from the date
on which the person becomes liable to registration [Section 25 read
with rule 10]. Therefore, the effective date of registration is 1st
September.

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 REGISTRATION 9.93

(b) Since in the given case, the turnover of Mehta Teleservices exceeds
the applicable threshold limit [` 20 lakh] on 25th October, it becomes
liable to registration on said date.
Further, since the application for registration has been submitted after
30 days from the date such person becomes liable to registration, the
registration shall be effective from the date of grant of registration.
Therefore, the effective date of registration is 5th December.
2. A Permanent Account Number is mandatory to be eligible for grant of
registration. One of the exceptions to this is a non-resident taxable person.
A non-resident taxable person may be granted registration on the basis of
other prescribed documents instead of PAN. He has to submit a self-attested
copy of his valid passport along with the application duly signed or verified
through electronic verification code by his authorized signatory who is an
Indian Resident having valid PAN and application will be submitted in a
different prescribed form [Section 25(6) & (7)].
3. (a) Section 22 stipulates that every supplier becomes liable to registration
if his turnover exceeds the applicable threshold limit in a financial year.
However, as per section 24, a person making taxable supply of
goods/services or both on behalf of other taxable persons whether as
an agent or not is liable to be compulsorily registered even if its
aggregate turnover does not exceed the applicable threshold limit
during the financial year.
(b) As per section 23, an agriculturist who is engaged exclusively in supply
of produce out of cultivation of land is not required to obtain
registration even if his turnover exceeded the applicable threshold limit
for registration.
4. As per section 22 read with Notification No. 10/2019 CT dated 07.03.2019, a
supplier is liable to be registered in the State/Union territory from where he
makes a taxable supply of goods and/or services, if his aggregate turnover in
a financial year exceeds the threshold limit. The threshold limit for a person
making exclusive intra-State taxable supplies of goods is as under:-
(a) ` 10 lakh for the Special Category States of Mizoram, Tripura, Manipur
and Nagaland.
(b) ` 20 lakh for the States, namely, States of Arunachal Pradesh,
Meghalaya, Puducherry, Sikkim, Telangana and Uttarakhand.

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 9.94 GOODS AND SERVICES TAX

(c) ` 40 lakh for rest of India except persons engaged in making supplies
of ice cream and other edible ice, whether or not containing cocoa, pan
masala and tobacco and manufactured tobacco substitutes, fly ash
bricks; fly ash aggregates; fly ash blocks, bricks of fossil meals or similar
siliceous earths, building bricks, earthen or roofing tiles.
The threshold limit for a person making exclusive taxable supply of services
or supply of both goods and services is as under:-
(a) ` 10 lakh for the Special Category States of Mizoram, Tripura, Manipur
and Nagaland.
(b) ` 20 lakh for the rest of India.
As per section 2(6), aggregate turnover includes the aggregate value of:

(i) all taxable supplies,

(ii) all exempt supplies,
(iii) exports of goods and/or services and

(iv) all inter-State supplies of persons having the same PAN.

The above aggregate turnover is computed on all India basis. Further, the
aggregate turnover excludes central tax, State tax, Union territory tax,
integrated tax and cess. Moreover, the value of inward supplies on which tax
is payable under reverse charge is not taken into account for calculation of
‘aggregate turnover’.
Section 9(2) provides that CGST is not leviable on five petroleum products i.e.
petroleum crude, motor spirit (petrol), high speed diesel, natural gas and
aviation turbine fuel. As per section 2(47), exempt supply includes non-
taxable supply. Thus, supply of high speed diesel in Delhi, being a non-
taxable supply, is an exempt supply and is, therefore, includible while
computing the aggregate turnover.
In the backdrop of the above-mentioned discussion, the aggregate turnover
of Pure Oils for the month of April is computed as under:

S. No. Particulars Amount (in `)

(i) Supply of machine oils in Delhi 15,00,000

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 REGISTRATION 9.95

(ii) Add: Supply of high speed diesel in Delhi 10,00,000

(iii) Add: Supply of machine oil made by Pure Oils 10,00,000

from its branch located in Punjab

Aggregate Turnover 35,00,000

Pure Oils is making exclusive supply of goods and hence the threshold limit
for registration would be ` 40,00,000. Since the aggregate turnover does not
exceed ` 40,00,000, Pure Oils is not liable to be registered till April. However,
if in remaining months of the financial year, its turnover exceeds the said limit,
then it would be liable to be registered.
5. In case Pure Oils makes the supply in capacity of an agent of Mixed Oils Ltd.:
Section 24 provides that an agent who is engaged in making taxable
supplying of goods on behalf of other taxable persons, shall be liable to
obtain registration irrespective of the threshold turnover limit. However, in
the present case, if Pure Oils supply high speed diesel on behalf of Mixed Oil
Ltd. in Delhi as its agent where invoices to customers are issued in name of
Pure Oils, it shall still not be liable to obtain registration in Delhi since section
24 comes into play only when agent or in other capacity is making taxable
supply of goods on behalf of taxable persons (principal) whereas in the given
case, Pure Oils is supplying non-taxable goods on behalf of Mixed Oils Ltd.,
who is not registered.
6. As per section 22 read with Notification No. 10/2019 CT dated 07.03.2019, a
supplier is liable to be registered in the State/Union territory from where he
makes a taxable supply of goods and/or services, if his aggregate turnover in
a financial year exceeds the threshold limit. The threshold limit for a person
making exclusive intra-State taxable supplies of goods is as under:-
(a) ` 10 lakh for the Special Category States of Mizoram, Tripura, Manipur
and Nagaland.

(b) ` 20 lakh for the States, namely, States of Arunachal Pradesh,

Meghalaya, Puducherry, Sikkim, Telangana and Uttarakhand.
(c) ` 40 lakh for rest of India except persons engaged in making supplies
of ice cream and other edible ice, whether or not containing cocoa, pan
masala and tobacco and manufactured tobacco substitutes, fly ash

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 9.96 GOODS AND SERVICES TAX

bricks; fly ash aggregates; fly ash blocks, bricks of fossil meals or similar
siliceous earths, building bricks, earthen or roofing tiles.
In the light of the afore-mentioned provisions, the answer to the independent
cases is as under:-
(i) Raghav is eligible for higher threshold limit of turnover for registration,
i.e. ` 40 lakh as he is exclusively engaged in intra-State supply of goods.
However, since Raghav is engaged in supplying readymade garments
from a Special Category State i.e. Tripura, the threshold limit gets
reduced to ` 10 lakh. Thus, Raghav is liable to get registered under GST
as his turnover has exceeded limit of `10 lakh. Further, he is required
to obtain registration in both Assam and Tripura as he is making taxable
supplies from both the States.
(ii) The applicable threshold limit for GST registration for Pulkit in the given
case is ` 40 lakh as he is exclusively engaged in intra-State taxable
supply of goods in Goa. Thus, he is not liable to get registered under
GST as his turnover is less than the threshold limit.
(iii) Harshit being exclusively engaged in supply of pan masala is not eligible
for higher threshold limit of `40 lakh. The applicable threshold limit for
registration in this case is `20 lakh. Thus, Harshit is liable to get
registered under GST.
7. As per section 22 read with Notification No. 10/2019 CT dated 07.03.2019, a
supplier is liable to be registered in the State/Union territory from where he
makes a taxable supply of goods and/or services, if his aggregate turnover in
a financial year exceeds the threshold limit. The threshold limit for a person
making exclusive taxable supply of services or supply of both goods and
services is as under:-
(a) ` 10 lakh for the Special Category States of Mizoram, Tripura, Manipur
and Nagaland.
(b) ` 20 lakh for the rest of India.
(i) Though Ankit is dealing in Assam, he is not entitled for higher
threshold limit for registration as the same is applicable only in
case of exclusively supply of goods and he is exclusively engaged

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 REGISTRATION 9.97

in providing services. Thus, the applicable threshold limit for

registration in this case is ` 20 lakh and hence, Ankit is liable to
get registered under GST.
(ii) Since Sanchit is engaged in supply of both taxable goods and
services, the applicable threshold limit for registration in his case
is ` 20 lakh. Thus, Sanchit is liable to get registered under GST as
his turnover is more than the threshold limit.
8. Registration will confer following advantages to the business:
 Legally recognized as supplier of goods or services.
 Proper accounting of taxes paid on the input goods or services which
can be utilized for payment of GST due on supply of goods or services
or both by the business.
 Legally authorized to collect tax from his purchasers and pass on the
credit of the taxes paid on the goods or services supplied to purchasers
or recipients.
 Become eligible to avail various other benefits and privileges rendered
under the GST laws.
9. No, a person without GST registration can neither collect GST from his
customers nor can claim any input tax credit of GST paid by him.
10. No. Every person who is liable to take a registration will have to get registered
separately for each of the States from where he makes taxable supply(ies)
provided his aggregate turnover exceeds applicable threshold limit in a
financial year.
11. Yes. In terms of the proviso to sub-section (2) of section 25, a person [Link]
multiple places of buiness in a State may obtain a separate registration for
each place of business, subject to such conditions as may be prescribed.
12. Yes. In terms of sub-section (3) of section 25, a person, though not liable to
be registered under sections 22 or 24 may get himself registered voluntarily,
and all provisions of the GST law, as are applicable to a registered person,
shall apply to such person.
13. Yes. In terms of sub-section (8) of section 25, where a person who is liable to
be registered under GST law fails to obtain registration, the proper officer
may, without prejudice to any action which may be taken under CGST Act, or

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 9.98 GOODS AND SERVICES TAX

under any other law for the time being in force, proceed to register such
person in the manner as prescribed in the CGST Rules.
14. Yes, the registration certificate once granted is permanent unless
surrendered, cancelled or suspended.
15. In terms of section 25(9), all notified UN bodies, Consulate or Embassy of
foreign countries and any other class of persons as may be notified would be
required to obtain a unique identification number (UIN) from the GST portal.
The structure of the said ID would be uniform across the States in conformity
with GSTIN structure and the same will be common for the Centre and the
States. This UIN will be needed for claiming refund of taxes paid on notified
supplies of goods and services received by them, and for any other purpose
as may be notified.
16. The taxable supplier making supplies to UN bodies is expected to mention
the UIN on the invoices and treat such supplies as if supplies are made to
another registered person (B2B).
17. In terms of section 27(1) read with proviso thereto, the certificate of
registration issued to a “casual taxable person” or a “non-resident taxable
person” shall be valid for a period specified in the application for registration
or 90 days from the effective date of registration, whichever is earlier.
However, the proper officer, at the request of the said taxable person, may
extend the validity of the aforesaid period of 90 days by a further period not
exceeding 90 days.
18. In such cases, the registration may be cancelled from such date, including any
retrospective date, as may deem fit by the proper officer [Section 29(2)(e)].
19. No, the tax paper has to take separate registration in every State from where
he makes taxable supply of services.
20. The transferee or the successor shall be liable to be registered with effect
from the date of such transfer or succession and he will have to obtain a fresh
registration with effect from the date of such transfer or succession [Section
22(3)].
21. Yes. The principal place of business and place of business have been
separately defined under sections 2(89) & 2(85) respectively. The taxpayer will
have to declare the principal place of business as well as the details of
additional places of business in the registration form.

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 REGISTRATION 9.99

22. Yes, as per section 29(3), the cancellation of registration under this section
shall not affect the liability of the person to pay tax and other dues under this
Act or to discharge any obligation under this Act or the rules made
thereunder for any period prior to the date of cancellation whether or not
such tax and other dues are determined before or after the date of
cancellation.
Further, as per section 29(5), every registered taxable person whose
registration is cancelled shall pay an amount, by way of debit in the electronic
credit ledger or electronic cash ledger, equivalent to the credit of input tax in
respect of inputs held in stock and inputs contained in semi-finished or
finished goods held in stock or capital goods or plant and machinery on the
day immediately preceding the date of such cancellation or the output tax
payable on such goods, whichever is higher, calculated in prescribed manner.

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 9.100 GOODS AND SERVICES TAX

R A P I D Q U I Z

•What is the treatment of exports while computing aggregate turnover?

1

•What is the treatment of value of inward supplies on which tax is payable

2 under reverse charge while computing aggregate turnover?

•What is the applicable threshold limit for registration if the person is

3 carrying out business of umbrellas and rain coats in Meghalaya?

•What is the treatment of CGST and SGST while computing aggregate

4 turnover?

•What is the treatment of outward supplies taxable under reverse charge

5 while computing ‘aggregate turnover’ of the supplier of such supplies?

•State whether Mr. X engaged in making supplies of ice cream in Gujarat

is required to obtain registration if his aggregate turnover in the financial
6 year is ` 25 lakh.

•What is the effective date of registration if application is submitted after

7 30 days of the applicant becoming liable to registration?

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 REGISTRATION 9.101

C R S S W O R D

3 4

7 8

ACROSS
2. An agriculturist to the extent of supply of produce out of cultivation of------
----is not liable to registration.
4. Aggregate turnover to include total turnover of all branches (i.e. all GST
registrations) under same ----------. (Acronym)

5. Inter-State supplies are----------while computing aggregate turnover.

6. --------person means a person who is registered or liable to be registered
under section 22 or section 24
7. A person who has obtained more than one registration in one State shall, in
respect of each such registration, be treated as---------persons.

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 9.102 GOODS AND SERVICES TAX

DOWNWARDS
1. Every supplier of goods is required to obtain registration in the State from
where he makes the-------- supply, if his aggregate turnover exceeds
specified threshold limit.
3. A business entity having its branches in multiple States will have to take-----
--State-wise registration for its branches in different States.

8. Proper officer can cancel registration on his own if registered person who is
monthly return filer, has not furnished returns for a continuous period of----
----- months.

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