GOODS & SERVICES TAX CA KARAN CHANDWANI

CHAPTER 6 - REGISTRATION

GENERAL PROVISIONS

Registration under any taxation system is necessary for identification of tax payers ensuring tax compliance
in the economy. Under indirect tax regime, without registration, a person can neither collect tax from his
customers nor claim any credit of tax paid by him.

ADVANTAGES OF REGISTRATION
 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.

NO CENTRALISED REGISTRATION
Under GST, registrations need to be taken State-wise, i.e. there are no centralized registrations under GST. A
business entity having its branches in multiple States will have to take separate State wise registration for the
branches in different States.

One registration per State:

Further, within a State, an entity with different branches would have single registration wherein it can declare
one place as principal place of business (PPoB) and other branches as additional place(s) of business (APoB).

Separate registration in respect of multiple places of business within a State:

However, a business entity having separate places of business in a State may obtain separate registration for
each of its place of business otherwise a given PAN based legal entity would have one registration number -
Goods and Services Tax Identification Number (GSTIN) per State.

NO TAX SPECIFIC REGISTRATION

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 cesses.

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BARE ACT – SECTION 22 – PERSONS LIABLE FOR REGISTRATION

(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.

(2) Every person who, on the day immediately preceding the appointed day, is registered or holds a licence
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, demerger 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: 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;
(ii) the supply of goods, after completion of job work, by a registered job worker shall be treated as the
supply of goods by the principal referred to in section 143, and the value of such goods shall not be included
in the aggregate turnover of the registered job worker;
(iii) the expression "special category States" shall mean the States as specified in subclause (g) of clause (4)
of article 279A of the Constitution 3[except the State of Jammu and Kashmir and States of Arunachal Pradesh,
Assam, Himachal Pradesh, Meghalaya, Sikkim and Uttarakhand.

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ANALYSIS OF SECTION 22 – PERSONS LIABLE FOR REGISTRATION

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 ₹ 20 lakhs.

However, 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 ₹ 10
lakh.

However, the Government may, at the request of a special category State and on the recommendations of
the Council, enhance the aggregate turnover from ₹ 10 lakh to such amount, not exceeding ₹ 20 lakh and
subject to such conditions and limitations, as may be so notified.

The Government may, at the request of a State and on the recommendations of the Council, enhance the
aggregate turnover from ₹ 20 lakh to such amount not exceeding ₹ 40 lakh in case of supplier who is engaged
exclusively in the supply of goods, subject to such conditions and limitations, as may be notified.

Explanation: 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.

Special Category States for the purpose Section 22:

Only Mizoram, Tripura, Manipur and Nagaland are Special Category States for the purpose of section 22.
Thus, the threshold limit of ₹ 10 lakhs is applicable for the State of Manipur, Mizoram, Nagaland, and Tripura.
It must be noted that if a person having place of business in different States across India has one branch in
any of the States being Manipur, Mizoram, Nagaland, and Tripura, the threshold limit for GST registration will
be reduced to ₹ 10 lakh.

It must be noted that the Central Government vide Notification No. 10/2019-CT dated 07-03-2019 w.e.f. 01-
04-2019 has provided that any person, who is engaged in exclusive supply of goods and whose aggregate
turnover in the financial year does not exceed ₹ 40 lakh is exempt from obtaining registration.
However, the exemption is not applicable for the following persons:

(a) persons required to take compulsory registration under section 24 of the Act;
(b) persons engaged in making supplies of the goods being:
(i) Ice cream and other edible ice, whether or not containing cocoa,
(ii) Pan masala, and
(iii) Tobacco and manufactured tobacco substitutes.
(c) persons engaged in making intra-State supplies in the States of Arunachal Pradesh, Manipur, Meghalaya,
Mizoram, Nagaland, Puducherry, Sikkim, Telangana, Tripura, Uttarakhand; and
(d) persons exercising option of voluntary registration or such registered persons who intend to continue
with their registration under the Act.

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Present position of registration in respect of exclusive suppliers of goods is as follows:

SR. NO. THRESHOLD STATE

1. Upto ₹ 10 lakhs Manipur; Mizoram; Nagaland; Tripura.

2. Upto ₹ 20 lakhs Specified States:

Arunachal Pradesh, Meghalaya, Sikkim and Uttarakhand.
Other than Specified States/UT: Telangana, Puducherry.

3. Upto ₹ 40 lakhs for goods Jammu and Kashmir; Assam; Himachal Pradesh;
& Rs. 20 lakhs for services All States other than 1 and 2.

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ANALYSIS OF AGGREGATE TURNOVER

1. Aggregate turnover to Aggregate turnover of persons having the same

include total turnover of Permanent Account Number is to be computed
all branches with same on all India basis.
PAN
For example: A dealer 'D' has two offices - one in
Rajasthan and another in Madhya Pradesh. In
order to determine whether 'D' is liable for
registration, turnover of both the offices would
be taken into account and only if the same
exceeds ₹ 40 lakh, 'D' is liable for registration.

2. Outward Supplies taxed It must be noted that Outward Supplies taxable under reverse charge would
on reverse charge basis - continue to be part of the 'aggregate turnover' of the supplier of such
to be included in supplies.
turnover of the supplier

3. Aggregate turnover to "Aggregate turnover" shall include all supplies made by the taxable person,
include all supplies whether on his own account or made on behalf of all his Principals.
made on behalf of
principal For example: Ragini Enterprises has appointed M/s. Kamal & Associates as
its agent. All the supplies of goods made by M/s. Kamal & Associates as
agent of Ragini Enterprises will also be included in the aggregate turnover
of M/s. Kamal & Associates.

4. Supply of goods by Job- The supply of goods, after completion of job-work, by a registered job-
worker to be included in worker shall be treated as the supply of goods by the principal, and the
supplies of Principal value of such goods shall not be included in the aggregate turnover of the
registered job-worker.

5. 'Aggregate turnover' The aggregate turnover is different from turnover in a State. The former
vs is used for determining the threshold limit for registration as well as
'Turnover in a State' eligibility for composition scheme. However, the composition levy in
respect of suppliers of goods as well as for service suppliers would be
calculated on the basis of 'turnover in the State'. Besides this in case of
the distribution of credit that is attributable to two or more units of the
person, the credit shall be distributed amongst such units on a pro rata
basis (i.e., ratio of their respective 'turnover in State' to the aggregate of
the 'turnover in State' of all such units).

6. No centralized Every supplier liable for registration will have to take a separate registration
registration in every state even though such supplier may be supplying goods or
services or both from more than one State as a single entity.

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Examples:
 Hemant of Himachal Pradesh is exclusively engaged in intra-State supply of furniture. His aggregate
turnover in the current financial year is ₹ 25 lakh. In view of the discussion in the above paras, the
applicable threshold limit for registration for Hemant 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, Hemant is exclusively engaged in supply of ice-
cream instead of furniture, 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, Hemant will be liable to get
registered under GST.

If instead of ice-cream, Hemant is exclusively engaged in supply of taxable services, the applicable
threshold limit for registration will still be ₹ 20 lakh. Thus, Hemant will be liable to get registered under
GST.

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

 Sultan of Telangana is exclusively engaged in intra-State supply of leather products. Its aggregate turnover
in the current financial year is ₹ 25 lakh.

Since Sultan 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 Sultan 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, Sultan is exclusively engaged in supply of taxable
services instead of leather products, the applicable threshold limit for registration will still be ₹ 20 lakh.
Thus, Sultan will be liable to get registered under GST.

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

 Karmveer of Mizoram is exclusively engaged in intra-State supply of toys. Its aggregate turnover in the
current financial year is ₹ 15 lakh. Since Karmveer is making taxable supplies from Mizoram which is a
Special Category State, the applicable threshold limit for registration for Karmveer 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, Karmveer is exclusively engaged in supply of
taxable services instead of toys, the applicable threshold limit for registration will still be ₹ 10 lakh. Thus,
Karmveer will be liable to get registered under GST. Further, if Karmveer 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, Karmveer will be liable to get registered under GST.

 Ramesh of Assam is exclusively engaged in intra-State supply of footwear. Its turnover in the current FY
from Assam showroom is ₹ 28 lakh. It has another showroom in Tripura with a turnover of ₹ 11 lakh in
the current FY. Since Ramesh is engaged in supplying footwear from a Special Category State, the
applicable threshold limit for him gets reduced to ₹ 10 lakh. Further, Ramesh is liable to get registered
under GST in both Assam and Tripura on his aggregate turnover crossing the threshold limit of ₹ 10 lakh.

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Registration required only for a place of business from where taxable supply takes place:
A person is required to obtain registration with respect to his each place of business in India from where a
taxable supply has taken place. However, a supplier is not liable to obtain registration in a State/UT from
where he makes an exempt/non-taxable supply.

Example: Mishra Enterprises is engaged in supply of taxable goods in Maharashtra. It also supplies alcoholic
liquor for human consumption from Nagaland. Its turnover in the current financial year is ₹ 34 lakh in
Maharashtra and ₹ 8 lakh in Nagaland. Since Mishra Enterprises is exclusively engaged in making taxable
supplies of goods from Maharashtra, the applicable threshold limit for obtaining registration is ₹ 40 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) are non-taxable supplies.

In the given case, since the aggregate turnover of Mishra Enterprises exceeds the applicable threshold limit
of ₹ 40 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 said State.

Transfer of business - Transferee to obtain fresh registration:

Where a business carried on by a taxable person registered under this Act is transferred, whether on account
of succession or otherwise [including transfer/change in the ownership of business due to death of the sole
proprietor], 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.

Transfer pursuant to scheme for amalgamation/ demerger - Transferee liable to be registered from date of
incorporation:
In a case of transfer pursuant to sanction of a scheme or an arrangement for amalgamation or, as the case
may be, demerger 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.

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BARE ACT – SECTION 23 – PERSONS NOT LIABLE FOR REGISTRATION

(1) The following persons shall not be liable to registration, namely:

(a) 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 this Act or under the Integrated Goods and Services
Tax Act;
(b) an agriculturist, to the extent of supply of produce out of cultivation of land.

(2) 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.

ANALYSIS OF SECTION 23

Agriculturist: [Section 2(7)]

An agriculturist, to the extent of supply of produce out of cultivation of land.
"Agriculturist" means an individual or a Hindu Undivided Family 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.

The following aspects need to be noted:

 An agriculturist is not liable to obtain registration under the Act to the extent of supply of produce out of
cultivation of land.
 The scope of the definition is restricted to an Individual or a Hindu Undivided Family. Any other "person"
as defined in Section 2(84), carrying on the activity of agriculture will not be considered as an agriculturist
and hence will not be exempted from registration provisions as provided in Section 23 (l)(b), of the Act.

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NOTIFIED CATEGORY OF PERSONS - SECTION 23(2)

SUPPLIERS OF GOODS HAVING AGGREGATE TURNOVER NOT EXCEEDING ₹ 40 LAKH

Any person, who is engaged in exclusive supply of goods and whose aggregate turnover in the financial year
does not exceed Rs. 40 lakh, except:
(i) persons required to take compulsory registration u/s 24 of the said Act;
(ii) persons engaged in making supplies of the goods being-
(a) Ice cream and other edible ice, whether or not containing cocoa;
(b) Pan masala;
(c) Tobacco and manufactured tobacco substitutes.
(iii) persons engaged in making intra-State supplies in the States of Arunachal Pradesh, Manipur, Meghalaya,
Mizoram, Nagaland, Puducherry, Sikkim, Telangana, Tripura, Uttarakhand; and
(iv) persons exercising option of voluntary registration under the provisions of Section 25(3), or such
registered persons who intend to continue with their registration under the said Act.

PERSON MAKING INTERSTATE SUPPLIES OF TAXABLE SERVICES

HAVING AGGREGATE TURNOVER NOT EXCEEDING ₹ 20 LAKH

However, aggregate value of such supplies, to be computed on all India basis, should not exceed ₹ 10 lakh in
case of Special Category States of Mizoram, Tripura, Manipur and Nagaland as specified in Section 22.

Example: M/s. X & Co., located in Delhi, is engaged in supply of taxable goods in the neighbouring States of
Punjab and Haryana. Its aggregate turnover in current FY is ₹ 15 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, M/s. X & 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.

PERSONS ONLY ENGAGED IN MAKING TAXABLE SUPPLIES,

TOTAL TAX ON WHICH IS LIABLE TO BE PAID ON REVERSE CHARGE BASIS

The Central Government has specified the 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) of the said Act as the category of persons exempted from
obtaining registration under the aforesaid Act.

Example: Vakil and Associates is a law firm engaged exclusively in supplying legal consultancy services liable
to tax under reverse charge. 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.

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PERSONS MAKING INTER-STATE TAXABLE SUPPLIES OF NOTIFIED HANDICRAFT GOODS UP TO ₹ 20 LAKH

The Central Government has specified the following persons making inter-State supplies of goods have been
exempted from obtaining registration:
(a) Persons making inter-State taxable supplies of notified handicraft goods
(b) Persons making inter-State taxable supplies of notified products, 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 [Rs. 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 eway bill.

Example: HastShilp Pvt. Ltd., located in Rajasthan, is a supplier of taxable and notified handicraft goods. It
supplies these goods in the neighbouring States of Delhi and Haryana. Its aggregate turnover in the month
of April is ₹ 15 lakh. Although Hastshilp 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 exceed ₹ 20 lakh as it has availed the
exemption from registration under Notification No. 03/2018 IT.

CASUAL TAXABLE PERSONS MAKING TAXABLE SUPPLIES OF

HANDICRAFT GOODS AND HANDMADE SHAWLS, STOLES ETC.

The Central Government has specified casual taxable persons making taxable supplies of handicraft goods as
the category of persons exempted from obtaining registration. However, the aggregate value of such supplies,
to be computed on all India basis, does not exceed an amount of ₹ 20 lakhs in a financial year ( ₹ 10 lakh in
case of Special Category States of Mizoram, Tripura, Manipur and Nagaland).

Obtaining of PAN and Generation of E-way Bill:

The casual taxable persons mentioned above shall obtain a Permanent Account Number and generate an e-
way bill in accordance with the provisions of Rule 138 of the CGST Rules, 2017.

EXEMPTION AVAILABLE TO PERSONS

MAKING EXEMPT INTERSTATE
SUPPLIES OF HANDICRAFTS

The above exemption shall be available

to such persons who are making inter-
State taxable supplies of handicraft
goods and are availing the benefit of
Notification No. 3/2018-IT dated 22-10-
2018.

Exemption is also available to such

persons making inter-State taxable
supplies of the specified products when made by the craftsmen predominantly by hand even though some
machinery may also be used in the process.

However, the aggregate value of such supplies, to be computed on all India basis, does not exceed an amount
of ₹ 20 lakhs in a financial year ( ₹ 10 lakh in case of Special Category States of Mizoram, Tripura, Manipur
and Nagaland).

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Such persons making inter-State taxable supplies shall be required to obtain a Permanent Account Number
and generate an e-way bill in accordance with the provisions of rule 138 of the CGST Rules, 2017.

JOB-WORKERS ENGAGED IN MAKING

INTERSTATE SUPPLY OF SERVICES

The Central Government has specified the job

workers engaged in making inter-State supply
of services to a registered person as the
category of persons exempted from obtaining
registration.

However, nothing contained in this

notification shall apply to a job-worker:

(a) who is liable to be registered under Section 22(1) or who opts to take registration voluntarily under
Section 25(3) of the said Act; or

(b) who is involved in making supply of services in relation to the goods mentioned against serial number 5
(Jewellery, goldsmiths' and silversmiths' wares and other articles) in the Annexure to Rule 138 of the CGST
Rules, 2017.

SUPPLIERS OF SERVICES SUPPLYING

SERVICES THROUGH AN E-
COMMERCE PLATFORM

The Central Government has

exempted the persons making
supplies of services, other than
supplies specified under Section 9(5)
of the said Act through an electronic
commerce operator who is required
to collect tax at source under Section
52 of the said Act, and having an
aggregate turnover, to be computed
on all India basis, not exceeding an amount of ₹ 20 lakh in a financial year, as the category of persons
exempted from obtaining registration under the said Act.

However, the aggregate value of such supplies, to be computed on all India basis, should not exceed an
amount of Rs. 10 lakh in case of Special Category States of Mizoram, Tripura, Manipur and Nagaland.

SERVICES PROVIDED BY THE COMMISSION AGENT FOR SALE / PURCHASE OF AGRICULTURAL PRODUCE

This circular lays down the deciding factor to determine whether a particular principal-agent relationship falls
within the ambit of the Para 3 of Schedule I to CGST Act, 2017. Said circular clarifies it further, taking the help
of 4 different scenarios:

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. Mr. B identifies the buyers and sells
the agricultural produce on behalf of Mr. A for which he charges a commission from Mr. A.

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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. In cases
where the invoice is issued by Mr. B to the buyer, the former is an agent covered under Para 3. of Schedule I.

However, in cases 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 Para 3. Since services by any APMC/board/services
provided by the commission agents for sale or purchase of agricultural produce are exempt from GST, such
commission agents (even when they qualify as agent under Schedule I) are not liable to be registered in
accordance with provisions of section 23(l)(a).

Further, according to section 24(vii), 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, the requirement of compulsory
registration for commission agent, under the said clause shall arise when both the following conditions are
satisfied, namely:
(a) the principal should be a taxable person; and
(b) the supplies made by the commission agent should be taxable.
Generally, a commission agent under APMC Act makes supplies on behalf of an agriculturist. As per provisions
of section 23(l)(b), an agriculturist who supplies produce out of cultivation of land is not liable for registration
and therefore does not fall within the ambit of the term 'taxable person'.

Thus, a commission agent who is making supplies on behalf of such an agriculturist - not a taxable person -
is not liable for compulsory registration u/s 24(vii). However, where a commission agent is liable to pay tax
under reverse charge, such an agent will be required to get registered compulsorily u/s 24(iii) of the CGST
Act.

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BARE ACT – SECTION 24 - COMPULSORY REGISTRATION IN CERTAIN CASES

Notwithstanding anything contained

in sub-section (1) of section 22, the
following categories of persons shall
be required to be registered under
this Act:

(i) persons making any inter-State

taxable supply;

(ii) casual taxable persons making

taxable supply;

(iii) persons who are required to pay

tax under reverse charge;

(iv) person who are required to pay

tax under sub-section (5) of section
9;

(v) non-resident taxable persons making taxable supply;

(vi) persons who are required to deduct tax u/s 51, whether or not separately registered under this Act;

(vii) persons who make taxable supply of goods or services or both on behalf of other taxable persons
whether as an agent or otherwise;

(viii) Input Service Distributor, whether or not separately registered under this Act;

(ix) persons who supply goods or services or both, other than supplies specified under sub-section (5) of
section 9, through such electronic commerce operator who is required to collect tax at source u/s 52;

(x) every electronic commerce operator who is required to collect tax at source under section 52;

(xi) every person supplying online information and database access or retrieval services from a place outside
India to a person in India, other than a registered person; and

(xii) such other person or class of persons as may be notified by the Government on the recommendations
of the Council.

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ANALYSIS OF SECTION 24

REGISTRATION REQUIREMENTS: AB Pvt. Ltd., Pune provides house-keeping services.

The company supplies its services exclusively through an e-commerce website owned and managed by Hi-
Tech Indya Pvt. Ltd., Pune. The turnover of AB Pvt. Ltd. in the current financial year is ₹ 18 lakh. Advise AB
Pvt. Ltd. as to whether they are required to obtain GST registration. Will your advice be any different if AB
Pvt. Ltd. sells readymade garments exclusively through the e-commerce website owned and managed by Hi-
Tech Indya Pvt. Ltd.?

Compulsory Registration: Section 24 of the said Act enlists certain categories of persons who are mandatorily
required to obtain registration, irrespective of their turnover. Persons who supply goods or services or both
through such electronic commerce operator (ECO), who is required to collect tax at source under Section 52,
is one such person specified under Section 24(ix). However, where the ECO is liable to pay tax on behalf of
the suppliers of services under a notification issued under Section 9(5), the suppliers of such services are
entitled for threshold exemption. Besides this vide Notification No. 65/2017-CT dated 15-11-2017, it has
been provided that persons who are suppliers of service and supplying services through e-commerce
operator are not required to register under GST if their aggregate turnover is less than ₹ 20 lakhs per annum-
( ₹ 10 lakh in case of Special Category States of Mizoram, Tripura, Manipur and Nagaland).

E-commerce Operator: Section 2(45) of the CGST Act defines ECO as any person who owns, operates or
manages digital or electronic facility or platform for electronic commerce. Electronic commerce is defined
u/s 2(44) to mean the supply of goods or services or both, including digital products over digital or electronic
network.

Since Hi-Tech Indya Pvt. Ltd. owns and manages a website for e commerce where both goods and services
are supplied, it will be classified as an ECO under Section 2(45).

ECO liable for Registration: Notification No. 17/2017-CT (R) dated 28-06-2017 issued u/s 9(5) specifies
services by way of house-keeping, except where the person supplying such service through ECO is liable for
registration under Section 22(1), as one such service where the ECO is liable to pay tax on behalf of the
suppliers.

In the given case, AB Pvt. Ltd. provides house-keeping services through an ECO. It is presumed that Hi-Tech
Indya is an ECO which is required to collect tax at source under Section 52. However, house-keeping services
provided by AB Pvt. Ltd., which is not liable for registration under Section 22(1) as its turnover is less than
₹ 20 lakh, is a service notified under Section 9(5). Thus, AB Pvt. Ltd. will be entitled for threshold exemption
for registration and will not be required to obtain registration even though it supplies services through ECO.

Supply of goods through ECO - Supplier liable for Compulsory Registration: In the second case, AB Pvt. Ltd.
sells readymade garments through ECO. Such supply cannot be notified under Section 9(5) as only supplies
of services are notified under that Section. Therefore, in the second case, AB Pvt. Ltd. will not be entitled for
threshold exemption and will have to compulsorily obtain registration in terms of Section 24(ix).

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BARE ACT – SECTION 25 - PROCEDURE FOR REGISTRATION

(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
(28 of 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 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 (43 of
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.

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(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 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 recommendations 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 (18 of 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.

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(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
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 (46
of 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.

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ANALYSIS OF SECTION 25

APPLICATION TO BE MADE WITHIN 30 DAYS IN EVERY STATE / UT

IN WHICH SUCH PERSON IS LIABLE FOR REGISTRATION

Every person who is liable to be registered shall apply for registration in every such State or Union territory
in which he is so liable within 30 days from the date on which he becomes liable to registration, in such
manner and subject to such conditions as may be prescribed.

SUPPLIER MAKING SUPPLY FROM TWI

Registration to be obtained from nearest coastal State or Union territory.

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.

SEPARATE REGISTRATIONS FOR SEZ UNITS AND NON - SEZ UNITS:

A person having a unit, as defined in the SEZ Act, 2005, in a SEZ or being a SEZ developer shall have to apply
for a separate registration, as distinct from his place of business located outside the SEZ in the same State or
Union territory.

For example: Raheja Services Ltd. is engaged in taxable supply of services in Rajasthan. The turnover of Raheja
Services Ltd. exceeded ₹ 20 lakh on 1st September. It is liable to get registered by 1st October in the State of
Rajasthan.

ONE REGISTRATION PER STATE

A person seeking registration under this Act shall be granted a single registration in a State or Union territory.
Thus, if within a State, an entity with different branches would have single registration wherein it can declare
one place as principal place of business (PPoB) and other branches as additional place of business (APoB).

SEPARATE REGISTRATION FOR MULTIPLE PLACE OF BUSINESS IN A STATE/ UT

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.

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.

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 shall not 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 relating to verification and grant of registration shall mutatis mutandis
apply to an application submitted under this rule

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VOLUNTARY REGISTRATION - ALL PROVISIONS OF REGISTRATION APPLICABLE

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.

ADVANTAGES OF VOLUNTARY REGISTRATION

Voluntary registration is advantageous for the persons which supply of goods or services or both to registered
persons. The reason for the same is that by virtue of Section 9(4) of the CGST Act, in case of supplies of
notified goods and services received from unregistered supplier by registered recipient, recipient has to pay
the tax under reverse charge.

Therefore, business units would prefer receiving supplies from the registered persons only. Thus, voluntary
registration enables a supplier of goods or services or both to enhance its business to business transactions.
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.

PERSON HAVING MORE THAN ONE REGISTRATION

EACH SUCH REGISTRATION TO BE TREATED AS DISTINCT PERSONS

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.

PREMISES IN SEPARATE STATES - DEEMED DISTINCT PERSONS

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.

PAN MANDATORY FOR OBTAINING REGISTRATION

Every person shall have a Permanent Account Number issued under the Income-tax Act, 1961 in order to be
eligible for grant of registration.

TAN mandatory: However, 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.

AUTHENTICATION OF REGISTERED PERSON BY AADHAAR NUMBER

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.

Alternate means of authentication if Aadhaar number not assigned: However, 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. Authentication
failure - Registration Invalid : 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.

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AUTHENTICATION BY AADHAAR NUMBER FOR GRANT OF REGISTRATION

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 of the Council, specify in the said notification.

Alternate means of authentication if Aadhaar number not assigned: 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.

Vide Notification No. 18/2020-CT dated 23-03-2020, the Central Government has notified 01-04-2020 as the
date from which an individual shall undergo authentication, of Aadhaar number, as specified in rule 8 of the
CGST Rules, 2017, in order to be eligible for registration.

NON INDIVIDUALS - AUTHENTICATION BY AADHAAR NUMBER OF AUTHORISED PERSONS

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 recommendations of the Council, specify in the
said notification.

Alternate means of authentication if Aadhaar number not assigned: 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.

The Central Government vide Notification No. 19/2020 dated 23-03-2020 has notified 01-04-2020, as the
date, from which the:
(a) authorised signatory of all types;
(b) Managing and Authorised partners of a partnership firm; and
(c) Karta of an Hindu undivided family,

shall undergo authentication of possession of Aadhaar number, as specified in rule 8 of the CGST Rules, 2017,
in order to be eligible for registration under GST.

NON-APPLICABILITY

The provisions of Section 25(6A)/(6B)/(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.

Aadhaar number: It shall have the same meaning as assigned to it in section 2(a) of the Aadhaar (Targeted
Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016.

Class of persons who do not require Aadhaar authentication or furnishing of proof of Aadhaar number at the
time of grant of registration.

The Central Government has notified the following class of persons on whom the provisions of Aadhar
authentication for grant of registration shall not apply:
(a) a person who is not a citizen of India; or

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(b) a Department or establishment of the Csentral Government or State Government; or

(c) a local authority; or
(d) a statutory body; or
(e) a Public Sector Undertaking; or
(f) a person applying for registration under the provisions of sec. 25(9) of the CGST Act i.e. UIN Holders.

NON-RESIDENT TAXABLE PERSON - REGISTRATION CAN BE GRANTED ON BASIS OF OTHER DOCUMENTS

A non-resident taxable person may be granted registration on the basis of such other documents as may be
prescribed.

FAILURE TO OBTAIN REGISTRATION - MANDATORY REGISTRATION

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 law for the time
being in force, proceed to register such person in such manner as may be prescribed.

UNIQUE IDENTITY NUMBER (UIN) TO BE GRANTED TO SPECIALIZED AGENCY

OF UNO/ CONSULATE/ EMBASSY OF FOREIGN COUNTRY/ OTHER NOTIFIED PERSONS

Notwithstanding anything contained in sec. 25(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.

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.

RC UIN to be granted or rejected after due verification:

The registration or the Unique Identity Number shall be granted or rejected after due verification within 3
working days from the date of submission of application.

RC to be issued in Prescribed Form:

A certificate of registration shall be issued in such form and with effect from such date as may be prescribed.

RC/UIN not granted within prescribed period - Deemed to be Granted:

A registration or a Unique Identity Number shall be deemed to have been granted after the expiry of the
period prescribed under Section 25(10), if no deficiency has been communicated to the applicant within that
period.

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PROCEDURE FOR MAKING APPLICATION FOR REGISTRATION - RULE 8 OF CGST RULES, 2017

DECLARATION OF PAN, MOBILE NUMBER, E-MAIL MANDATORY

Every person, other than:

> a non-resident taxable person,
> a person required to deduct tax at source under Section 51,
> a person required to collect tax at source under Section 52, and
> a person supplying online information and database access or retrieval services from a place outside India
to a non-taxable online recipient referred to in Section 14 of the IGST Act, 2017 who is liable to be
compulsorily registered under Section 25(1) and every person seeking voluntary registration under Section
25(3) shall, before applying for registration, declare his:

> Permanent Account Number, > mobile number, > e-mail address,
> State or Union territory
in Part A of FORM GST REG-01 on the common portal, either directly or through a Facilitation Centre notified
by the Commissioner.

SEPARATE APPLICATION FOR REGISTRATION AS ISD

Every person being an Input Service Distributor shall make a separate application for registration as such
Input Service Distributor.

VALIDATION OF PAN/ MOBILE NUMBER/ E-MAIL

(a) The Permanent Account Number shall be validated online by the common portal from the database
maintained by the Central Board of Direct Taxes.
(b) The mobile number declared as above shall be verified through a one-time password sent to the said
mobile number; and
(c) The e-mail address declared as above shall be verified through a separate one-time password sent to the
said e-mail address.

TEMPORARY REFERENCE NUMBER

On successful verification of the Permanent Account Number, mobile number and email address, a
temporary reference number shall be generated and communicated to the applicant on the said mobile
number and e-mail address.

SUBMISSION OF APPLICATION

Using the reference number generated, the applicant shall electronically submit an application in Part B of
FORM GST REG-01, duly signed or verified through electronic verification code (EVC), along with the
documents specified in the said Form at the common portal, either directly or through a Facilitation Centre
notified by the Commissioner.

AADHAAR AUTHENTICATION

Where an applicant, other than a person notified under section 25(6D), opts for authentication of Aadhaar
number, he shall, while submitting the registration application, undergo authentication of Aadhaar number
and the date of submission of the application in such cases shall be the date of authentication of the Aadhaar
number, or 15 days from the submission of the application in Part B of FORM GST REG-01, whichever is earlier.

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E-ACKNOWLEDGEMENT

On receipt of an application under Rule 8(4), an acknowledgement shall be issued electronically to the
applicant in FORM GST REG-02.

TEMPORARY REFERENCE NUMBER FOR CASUAL TAXABLE PERSON

A person applying for registration as a casual taxable person shall be given a temporary reference number by
the common portal for making advance deposit of tax in accordance with the provisions of Section 27 and
the acknowledgement shall be issued electronically only after the said deposit.

VERIFICATION OF THE APPLICATION AND APPROVAL - RULE 9 OF CGST RULES, 2017

APPLICATION FOUND IN ORDER - APPROVAL TO GRANT RC WITHIN 7 WORKING DAYS

Every application made under rule (4) shall be followed by:

(a) biometric-based Aadhaar authentication and taking photograph, unless exempted u/s 25(6D), if he has
opted for authentication of Aadhaar number; or
(b) taking biometric information, photograph and verification of such other KYC documents, as notified,
unless the applicant is exempted u/s 25(6D), if he has opted not to get Aadhaar authentication done,

of the applicant where the applicant is an individual or of such individuals in relation to the applicant as
notified u/s 25(6C) where the applicant is not an individual, along with the verification of the original copy of
the documents uploaded with the application in FORM GST REG-01 at one of the Facilitation Centres notified
by the Commissioner for the purpose of this sub-rule and the application shall be deemed to be complete
only after completion of the process laid down under this sub-rule shall be forwarded to the proper officer
who shall examine the application and the accompanying documents and if the same are found to be in
order, approve the grant of registration to the applicant within a period of 7 working days from the date of
submission of the application.

However, where:
(a) a person, other than a person exempt from Aadhar authentication, fails to undergo authentication of
Aadhaar number or does not opt for authentication of Aadhaar number; or
(b) the proper officer, 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, after physical verification of the
place of business in the presence of the said person, in the manner provided under rule 25 and verification
of such documents as the proper officer may deem fit.

DEFICIENCY FOUND IN APPLICATION - E-NOTICE WITHIN 7 WORKING DAYS

Where the application submitted 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 FORM GST REG-03 within a period of 7 working days from the date of
submission of the application.

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However, where:
(a) a person, other than a person exempt from Aadhar authentication, fails to undergo authentication of
Aadhaar number or does not opt for authentication of Aadhaar number; or
(b) the proper officer, 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 notice in FORM GST REG-03 may be issued not later than 30 days from the date of submission of the
application.

E-CLARIFICATION, INFORMATION ETC. WITHIN 7 WORKING DAYS OF RECEIPT OF NOTICE

The applicant shall furnish such clarification, information or documents electronically, in FORM GST REG-04,
within a period of 7 working days from the date of the receipt of such notice.

Explanation: The purposes of this sub-rule, the expression "clarification" includes modification or correction
of particulars declared in the application for registration, other than Permanent Account Number, State,
mobile number and e-mail address declared in Part A of FORM GST REG-01.
APPROVAL TO GRANT REGISTRATION WITHIN 7 WORKING DAYS
FROM THE DATE OF RECEIPT OF SUCH CLARIFICATION OR INFORMATION OR DOCUMENTS

Where the proper officer is satisfied with the clarification, information or documents furnished by the
applicant, he may approve the grant of registration to the applicant within a period of 7 working days from
the date of the receipt of such clarification or information or documents.

REJECTION OF APPLICATION IF NO REPLY IS RECEIVED WITHIN 7 DAYS

Where no reply is furnished by the applicant in response to the notice or where the proper officer is not
satisfied with the clarification, information or documents furnished, he shall, for reasons to be recorded in
writing, reject such application and inform the applicant electronically in FORM GST REG-05.

DEEMED APPROVAL

If the proper officer fails to take any action:

(a) within a period of 7 working days from the date of submission of the application in cases where a person
successfully undergoes authentication of Aadhaar number or is exempt from Aadhaar authentication; or
(b) within a period of 30 days from the date of submission of the application in cases where a person is in
cases where a person fails to undergo Aadhaar authentication or does not opt for Aadhaar authentication;
or
(c) within a period of 7 working days from the date of the receipt of the clarification, information or
documents furnished by the applicant in cases where Proper Officer issues notice seeking clarification,
information or documents from the applicant,

the application for grant of registration shall be deemed to have been approved.

PHYSICAL VERIFICATION OF BUSINESS PREMISES IN CERTAIN CASES

Where the proper officer is satisfied that the physical verification of the place of business of a person is
required due to failure of Aadhaar authentication or due to not opting for Aadhaar authentication before the
grant of registration, or due to any other reason after the grant of registration, he may get such verification
of the place of business, in the presence of the said person, done and the verification report along with the
other documents, including photographs, shall be uploaded in FORM GST REG-30 on the common portal
within a period of 15 working days following the date of such verification.

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PROCEDURE FOR REGISTRATION

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