A BOOK BY CA VIJENDER AGGARWAL

SRCC, Delhi University

All India Topper At CA-Inter & CA-Final
Registration Under GST B. 21

TOPIC 9 - REGISTRATION UNDER GST

Person Liable For Registration On The Basis Of Aggregate Turnover {Section 22}:
Threshold Limit For Registration:
Supplier Of Services (+) Mixed Supplier Of Supplier Of Any Goods
Particulars
Supplier Of Goods & Services Specified Goods Other Than Specified Goods
Person Not Liable For Registration (+) Compulsory Registration In
Certain Cases {Combined Analysis Of Sections 23 & 24}:
Following Persons Not Liable For Registration {Section 23}:
++ Person engaged exclusively in supply of non-taxable goods/services/both.

Nagaland, Manipur, Tripura & Mizoram Rs 10L Rs 10L Rs 10L ++ Person engaged exclusively in supply of wholly exempted goods/services/both.

Uttarakhand, Puducherry, Meghalaya, ++ An agriculturist engaged exclusively in supply of produce obtained from cultivation of land.
Rs 20L Rs 20L Rs 20L ++ Person engaged exclusively in making supplies of goods/services on which entire tax is to be
Arunachal Pradesh, Sikkim & Telangana
paid by the recipient under reverse charge as per Section 9(3) of CGST Act.
Any Other State/UT Rs 20L Rs 20L Rs 40L
++ Other specified situations {as discussed u/s 24}.
Specified Goods: Total 7 Types Of Goods {Pan-Masala; Tobacco & Manufactured Tobacco Substitutes; Ice-Cream &
Following Persons Compulsorily Liable For Registration {Section 24}:
Other Edible Ice; Fly Ash Bricks/Blocks; Bricks Of Fossil Meals Or Similar Siliceous Earths; Building Bricks; Earthen
++ Effective Position In Case Of Inter-State Supplier Of Goods/Services:
Or Roofing Tiles}
Inter-State Supplier Of Goods Inter-State Supplier Of Services
Explanation To Section 22: 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 Registration is mandatory irrespective of the level of Registration required only if
consideration is represented by way of interest or discount. aggregate turnover. {Section 24} the aggregate turnover exceeds
Exception: Inter-state supplier of notified handicraft Rs 20L (Rs 10L in case of
Registration Required Only For A Place Of Business From Where Taxable Supply Takes Place: A supplier is not liable to
goods (made by the craftsmen predominantly by Nagaland, Manipur, Tripura &
obtain registration in a State/UT from where he makes only exempted/non-taxable supplies.
hand) not liable for registration if the aggregate value Mizoram).
Calculation Of Aggregate Turnover: of such supplies computed on all India basis does not {Combined Analysis Of
++ Turnover of all branches exceed Rs 20L (Rs 10L in case of Nagaland, Manipur, Sections 23 & 24}
across India having a common Tripura & Mizoram) and such supplier obtains a PAN
PAN has to be aggregated to and generates an e-way bill. {Section 23}
determine whether a dealer is ++ Person receiving supplies on which tax is payable by the recipient on reverse charge basis.
liable for registration or not.
++ Casual Taxable Person (CTP) {CTP means a person who occasionally undertakes transactions
++ All kinds of outward supplies made have to be considered at the time of computation of aggregate turnover.
involving supply of goods or services or both in the course or furtherance of business,
It is immaterial whether tax is payable under forward charge or reverse charge on such supplies. whether as principal, agent or in any other capacity, in a State/UT where he has no fixed
++ However, any tax chargeable under GST law as well as value of inward supplies on which tax is payable by the person place of business though he might be registered with regard to his fixed place of business
under reverse charge shall be excluded at the time of computation of aggregate turnover. in some other State/UT}.
++ Supplies made by an agent on behalf of a principal shall be included in the aggregate turnover of both the agent as Exception: CTP supplying notified handicraft goods (made by the craftsmen predominantly
well as the principal. by hand) not liable for registration if the aggregate value of such supplies computed on all
India basis does not exceed Rs 20L (Rs 10L in case of Nagaland, Manipur, Tripura & Mizoram)
Supplies Made From Branches Located In Different States/UTs With Varying Threshold Limits:
and such supplier obtains a PAN and generates an e-way bill. {Section 23}
++ Case 1 – Branch 1 Engaged In Taxable Supplies {Located In State/UT With Higher Threshold} & Branch 2 Also Engaged
In Taxable Supplies {Located In State/UT With Lower Threshold}: The lower threshold limit shall be applicable for both ++ Non-Resident Taxable Person (NRTP) {NRTP means any person who occasionally undertakes
the branches. If the aggregate turnover of both the branches exceeds the lower threshold limit, both the branches 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}.
would be liable for registration.
++ Agent supplying taxable goods/services on behalf of his principal {Section 24 not applicable
++ Case 2 – Branch 1 Engaged In Taxable Supplies (Located In State/UT With Higher Threshold) & Branch 2 Engaged
where an agent supplies non-taxable or exempted goods/services on behalf of his principal}.
In Non-Taxable/Exempted Supplies (Located In State/UT With Lower Threshold): Since Branch 2 is not engaged in
E-Commerce Operators {Section 24 is applicable irrespective of the fact whether ECO
taxable supplies, Branch 2 is not liable for registration. If the aggregate turnover of both the branches exceeds the
++
transactions are covered u/s 9(5) of CGST Act or not}.
higher threshold limit, Branch 1 would be liable for registration.
++ Suppliers supplying goods through an ECO provided the transaction has not been notified
Other Cases Where Registration Is Required: u/s 9(5) of CGST Act {Suppliers supplying services through an ECO have been exempted
++ In case of transfer of business as a going concern, the transferee/successor to be registered with effect from the from obtaining registration provided transaction has not been notified u/s 9(5) of CGST Act
date of such transfer/succession. and their aggregate turnover computed on all India basis does not exceed Rs 20L (Rs 10L in
++ In case of transfer of business as a result of amalgamation/demerger of two or more companies, the transferee is to case of Nagaland, Manipur, Tripura & Mizoram)}.
be registered with effect from the date on which the ROC issues a certificate of incorporation giving effect to such ++ Such other person or class of persons as may be notified by the Government on the
order. recommendations of the GST Council.
 A BOOK BY CA VIJENDER AGGARWAL
SRCC, Delhi University
All India Topper At CA-Inter & CA-Final
Registration Under GST B. 22

Registration Procedure {Section 25}:

Time Limit For Obtaining Registration & Effective Date Of Registration:
++ Application for registration to be given within 30 days from the date of becoming liable for registration.

++ If an application for registration is submitted within the prescribed time period of 30 days, the

effective date of registration shall be the date on which the person becomes liable for registration.
++ If an application for registration is submitted after the prescribed time period of 30 days, the

effective date of registration shall be the date of grant of registration.

++ Where a person makes supply from the territorial waters of India, registration is to be obtained in the

coastal State/UT where the nearest point of the appropriate base line is located.
Multiple Branches In Various States v/s Multiple Branches In Same State:
++ Under GST, there is no concept of centralized registration as registration needs to be taken

state-wise. A business entity having its branches in multiple states will have to take separate
state-wise registration for all its branches.
++ If an entity has multiple branches within a particular state, a single registration can be obtained

wherein one branch has to be declared as principal place of business whereas the other branches
can be declared as additional places of business. However, separate registration may be obtained
for multiple branches within a state, if required.
Note: Where multiple branches of one legal person are registered separately, they are deemed as
distinct persons for the purposes of GST law.
Aadhaar Authentication:
++ The following persons are required to undergo Aadhar authentication or furnish proof of possession

of Aadhaar number:
 ‘Proprietorship’ Registration - Individual
 ‘HUF’ Registration - Karta
 ‘Partnership Firm/LLP Firm’ Registration - Managing Partner/Authorised Partners
 ‘Company’ Registration - Managing Director/Whole Time Directors
 ‘AOP/BOI’ Registration - Members of Managing Committee
 ‘Trust’ Registration – Board of Trustees
 Registration Of Any Other Person - Authorised Signatory
++ If Aadhaar number is not assigned to the said persons, they shall be offered alternate and viable

means of identification, ie such person shall furnish the following identification documents:
1. Aadhaar Enrolment ID slip; and
2. Any one of the following documents:
 Bank passbook with photograph;
 Voter identity card issued by the Election Commission of India;
 Passport; or
 Driving license issued by the Licensing Authority.
Such person shall undergo the authentication of Aadhaar Number within a period of 30 days of the
Format Of GSTIN: GSTIN represents the 15-digit registration number allotted to a person after successful registration.
allotment of the Aadhaar Number.
++ First 2 Digits: State Code As Per Indian Census 2011 ++ 13th Digit: Number Of Registrations Within A State/UT
++ The provisions of Aadhar authentication shall not apply in case of the following persons:
(Every State Has A Unique Code) ++ 14th Digit: Alphabet ‘Z’ (By Default)
 Any person who is not an Indian citizen
++ Next 10 Digits (3rd Digit To 12th Digit): PAN ++ 15th Digit: Check Sum Character
 Any department/establishment of CG/SG
 Embassy/Consulates of foreign countries, specialised agencies of UNO or any Multilateral Financial Display Of Registration Certificate And GSTIN: Registration certificate needs to be displayed in a prominent location
Institution and Organisation notified under the United Nations (Privileges and Immunities) Act at principal place of business as well as at every additional place of business. Further, GSTIN needs to be displayed
 A local authority/statutory body/Public Sector Undertaking on the name board exhibited at the entry of principal place of business as well as at every additional place of
business.
 A BOOK BY CA VIJENDER AGGARWAL
SRCC, Delhi University
All India Topper At CA-Inter & CA-Final
Registration Under GST B. 23

Registration Requirements For Casual Taxable Person (CTP) & Non-Resident Taxable Person (NRTP) {Sections 25 & 27}
++ Registration mandatory irrespective of the threshold limit as per Section 24. Registration to be obtained atleast 5 days prior to the commencement of business; taxable supplies to be made only after the issuance of
certificate of registration. Further, tax to be deposited in advance equivalent to the estimated amount of tax liability for the period for which registration is sought.
++ Registration certificate to remain valid for the period specified in the registration application or 90 days from the effective date of registration, whichever is earlier.
++ Extension can be obtained for maximum 90 days by making an application before the end of the validity of registration along with deposit of additional amount of tax equivalent to the estimated tax liability for the period
for which the extension is sought.
++ Special Provisions For Only NRTP: Where a NRTP does not have a PAN, he may be granted registration on the basis of self-attested copy of his valid passport along with an application signed by his authorized signatory
who is a resident of India having a valid PAN. In case of a business entity incorporated or established outside India, tax identification number or unique number on the basis of which the entity is identified by the foreign
government also needs to be furnished.

Special Cases Relating To Registration: Amendment Of Registration {Section 28}:

Voluntary Registration:
A person who is not compulsorily required to obtain registration u/s 22 to 24 of CGST Act may get
himself registered voluntarily and all the provisions of GST law shall apply to such person as if he is a
registered taxable person. Where a person obtains voluntary registration, he has to pay tax even though
his aggregate turnover does not exceed the applicable threshold limit.
Unique Identity Number (UIN):
Specialized agencies of UNO, any
Multilateral Financial Institution/
Organization as notified under the
United Nations (Privileges and
Immunities) Act, 1947, foreign
embassies/consulates, etc are allowed
refund of taxes paid by them on
procurement of notified supplies of
goods and/or services used for notified
purposes. For this purpose, such
persons are required to obtain a UIN
from GST Common Portal. UIN granted is a Centralized-UIN (ie, it shall be applicable to the entire
territory of India). A person having a UIN is not treated as a registered person and thus, shall not be
considered as a taxable person.
Suo-Moto Registration By Proper Officer:
++ Where, pursuant to any survey, enquiry, inspection, search or any other proceedings, the Proper

Officer is of the opinion that a person has not got himself registered even though he was liable to be
registered, the Proper Officer may suo-moto register the said person on a temporary basis.
++ Where the person accepts the Proper Officer’s decision and decides not to file an appeal, such person

shall submit an application for permanent registration within next 90 days.

++ Where the person files an appeal against the decision of the Proper Office and the appeal is decided

in his favour, the Proper Officer shall drop the proceedings. However, if the appeal is decided in
Officer’s favour, the person shall submit an application for permanent registration within 30 days of
issuance of order.
Registration Of SEZ Developer & SEZ Units:
SEZ Developer/Units are entitled to claim refund of their unutilized ITC, therefore SEZ Developer/SEZ
Units are required to make a separate application for registration distinct from their other units located
outside SEZ.
 A BOOK BY CA VIJENDER AGGARWAL
SRCC, Delhi University
All India Topper At CA-Inter & CA-Final
Registration Under GST B. 24

Cancellation Of Registration {Sections 29 & 30}:

Cancellation In Genuine Bonafide Situations: In the following cases, registration can be Consequences Of Cancellation Of Registration:
cancelled either suo-moto by the Proper Officer or on an application for cancellation ++ Cancellation of registration will not affect liability of a registered person to pay tax and other dues under GST law for any period
made to him by the registered person/legal heirs: prior to the date of cancellation, whether or not such tax and other dues are determined before or after the date of cancellation.
++ Discontinuance of ++ Taxpayer would not be allowed by the GST Common Portal to file return for the period after the date of cancellation mentioned
business; in the cancellation order. However, he can submit returns of the earlier period (ie, for the period before the date of cancellation
++ Transfer of business mentioned in the cancellation order for which registration was active).
for any reason
Revocation Of Cancellation Of Registration {Section 30}:
including death of the
proprietor; Note 1: The period of 30 days may, on sufficient cause
being shown and for reasons to be recorded in writing,
++ Amalgamation with
be extended for a period upto 30 days by Additional/
any other entity;
Joint Commission and for a further period upto 30 days
++ Disposal of business by way of demerger or otherwise;
by the Commissioner.
++ Change in the constitution of the business; or
Note 2: Application for revocation of cancellation of
++ Taxable person is no longer liable to be registered u/s 22 or 24 of CGST Act.
registration cannot be made where the registration
Note: A person having a UIN cannot apply for cancellation of registration. was initially cancelled on the request of taxpayer/his
Cancellation In Doubtful Malafide Situations: In the following cases, registration can legal heirs. Further, GST Practitioners and UIN-Holders
be cancelled by the Proper Officer from such date, including any retrospective date, cannot apply for revocation of cancelled
as he may deem fit: registration.
++ A registered person does not conduct any business from the declared place of business;
Note 3: Where registration was cancelled
++ A voluntarily for failure of registered person to furnish
registered returns, the person has to make good the
person has defaults before applying for revocation, ie
failed to the person needs to file such returns and
commence pay any amount due as tax along with any
his business
amount payable towards interest, penalty
within six
and late fee in respect of the said returns.
months from
the date of Suspension Of Registration {Rule 21A Of CGST Rules}:
registration; In the following three cases, the Proper Officer may suspend the registration of a person during pendency of the proceedings
++ A registered relating to cancellation of his registration. A registered person, whose registration has been suspended, shall not make any
person issues taxable supply during the period of suspension and shall not be required to furnish any return u/s 39 {ie, the registered person
invoice/bill without supply of goods/services in violation of the provisions of CGST shall not issue a tax invoice and accordingly, not charge tax on supplies made by him during the period of suspension}.
Act or CGST Rules; ++ Registered Person Has Applied For Cancellation Of Registration: Registration shall be deemed to be suspended from the date
++ A composition taxpayer has not furnished his GSTR-4 for a FY beyond three months of submission of the application or the date from which the cancellation is sought, whichever is later.
from the due date of furnishing the said return; ++ Cancellation Of Registration Has Been Initiated By The Department On Its Own Motion: Registration shall be suspended with
++ A regular taxpayer has not furnished returns for continuous period of six months (in
effect from a date to be determined by the Proper Officer.
case of monthly filing of returns) or continuous period of two tax periods (in case
of quarterly filing of returns under QRMP scheme); ++ Significant Differences/Anomalies Discovered Post Comparative Analysis Leading To Cancellation Of Registration: Where, a
comparison of GSTR-3B furnished by a registered person u/s 39 with
++ A registered person avails ITC in violation of the provisions of CGST Act or CGST Rules;
 the details of outward supplies furnished by him in his own GSTR-1; or
++ A registered person violates the provisions of Rule 86B of CGST Rules;
 the details of inward supplies derived based on the details of outward supplies furnished by his suppliers in their respective
++ A registered person furnishes the details of outward supplies in Form GSTR-1 u/s 37
GSTR-1,
for one or more tax periods which is in excess of the outward supplies declared by
or such other analysis, as may be carried out on the recommendations of the Council, show that there are significant
him in his valid return u/s 39 for the said tax periods; or
differences or anomalies indicating contravention of the provisions of CGST Act or CGST Rules, leading to cancellation of
++ Registration has been obtained by means of fraud, wilful misstatement or suppression
registration of the said person, his registration shall be suspended.
of facts.