CA InterGST › Ch 9

Registration

Goods and Services Tax Paper 3, Sec B ~25 min revision Sec 22–30ProceduresTimelines

AI-assisted · review in progress · last updated 25 July 2026 · jump to quick revision

In 30 seconds

  1. The whole chapter is nine consecutive sections — 22 liable, 23 not liable, 24 compulsory, 25 procedure, 26 deemed, 27 CTP/NRTP, 28 amendment, 29 cancellation & suspension, 30 revocation.
  2. Registration is PAN-based and State-wise — no centralised registration; one registration per State covers CGST + SGST/UTGST + IGST + Cess, with separate registration per place of business optional.
  3. Thresholds: ₹20 lakh normally, ₹10 lakh in Manipur, Mizoram, Nagaland and Tripura, ₹40 lakh for exclusive goods suppliers — but Sec 24's 11 compulsory categories ignore every threshold.
  4. Core flow: cross the Sec 22 threshold OR fall in the Sec 24 list → unless Sec 23 exempts → REG-01 within 30 days → REG-06 certificate with a 15-digit GSTIN.
  5. Exam favourites are the timelines: 30/15/7/3-day ladders for application, amendment and cancellation, 90+90 days for CTP/NRTP validity, 90+180 days for revocation.
Quick-revision mode is on. Prose is hidden — definitions, key lists and tables only.

Based on GST law as on 30.04.2025 (May 2026 exams onwards). Section numbers are CGST Act unless stated.

How the chapter fits together

Registration has the friendliest structure in GST: the mnemonic “22-23-24-25-26-27-28-29-30” is the chapter — nine consecutive sections, each doing one job:

Key points
  • Sec 22 — liable to register (threshold ₹40/20/10 lakh) →
  • Sec 23 — NOT liable (exemptions) →
  • Sec 24 — COMPULSORY registration, no threshold (overrides Sec 22) — 11 categories →
  • Sec 25 — procedure (where/when/how; PAN; distinct persons; UIN; suo motu) →
  • Sec 26 — deemed registration (CGST↔SGST mirror) →
  • Sec 27 — CTP/NRTP special provisions (90 days, advance deposit) →
  • Sec 28 — amendment (core/non-core; 15 days) →
  • Sec 29 — cancellation & suspension → Sec 30 — revocation (90+180 days).

Four structural principles frame everything: GST registration is PAN-based and State-wise; there is no centralised registration; a single registration covers CGST + SGST/UTGST + IGST + Cess; and one State means one registration (covering the principal and additional places of business), with separate registration per place of business optional.

The flow of every question: turnover crosses the threshold (Sec 22) or the person falls in the Sec 24 list (no threshold) → unless Sec 23 exempts → apply in Form REG-01 within 30 daysREG-06 certificate with a GSTIN.

Key definitions

Definition

Aggregate turnover [Sec 2(6)]

All-India total for the same PAN: taxable + exempt + export + inter-State supplies. Excludes CGST/SGST/IGST/cess and inward RCM supplies. Traps: outward RCM supplies are included; exempt and non-taxable goods (petrol) are included; an agent’s turnover includes both his own and his principal’s supplies.

Definition

Casual taxable person [Sec 2(20)]

Occasional supplier with no fixed place of business in that State but a registered business elsewhere in India. The business test applies. Cannot opt for composition.

Definition

Non-resident taxable person [Sec 2(77)]

Occasional supplier with no fixed place of business or residence anywhere in India. No business test. Cannot opt for composition.

Definition

Agriculturist [Sec 2(7)]

An individual or HUF cultivating land by own/family/hired labour under personal supervision — companies and firms never qualify. The Sec 23 shelter covers only produce out of cultivation of land, and is lost if any other taxable supply is made.

Definition

Distinct persons [Sec 25(4)/(5)]

Every registration — in the same or a different State — is a separate person for GST. This applies even to multiple GSTINs within one State, and is critical for inter-branch supplies and ITC.

The remaining definitions, with their traps:

TermCrisp meaningTrap / keyword
Turnover in a StateUsed only to compute composition tax payableNot the threshold test — that is aggregate turnover
Taxable person [2(107)]Registered or liable to be registered u/s 22 or 24Unregistered-but-liable is still a taxable person; so is a voluntary registrant
Taxable supply [2(108)]Supply leviable to taxRegistration is needed from the place the taxable supply is made, not received
Agent [2(5)]Factor / broker / commission agent / arhatia / del credere agent / auctioneer acting on behalf of anotherAPMC commission agent is not an “agent” if the principal invoices directly
Fixed establishment [2(50)]Place with permanence + human/tech resourcesMere port landing or a liaison office is not a fixed establishment
UIN [25(9)]Given to UN bodies / embassies / notified persons for refundsUIN holder is not a registered person and not a taxable person
Registered person [2(94)]Person registered u/s 25Specifically excludes UIN holders

Liability — Sections 22, 23 and 24

Section 22(1) makes a person liable when aggregate turnover in a financial year exceeds ₹20 lakh (₹10 lakh in special category States), enhanced to ₹40 lakh for exclusive suppliers of goods. Memorise the State-wise ladder:

ThresholdStates
₹10 lakh (goods & services)Manipur, Mizoram, Nagaland, Tripura
₹20 lakh (goods & services)Arunachal Pradesh, Meghalaya, Sikkim, Uttarakhand, Puducherry, Telangana
₹20 lakh services/mixed + ₹40 lakh exclusive goodsJ&K, Assam, Himachal Pradesh, all other States

Note the two special-category lists: Article 279A(4)(g) names 11 States (Arunachal Pradesh, Assam, J&K, Manipur, Meghalaya, Mizoram, Nagaland, Sikkim, Tripura, Himachal Pradesh, Uttarakhand) — but only 4 of them (Mizoram, Tripura, Manipur, Nagaland) get the ₹10 lakh threshold; the other 7 follow the normal ₹40/20 lakh rule.

₹40 lakh exceptions (4) — even an exclusive goods supplier does not get ₹40 lakh if:

  • (a) covered by a Sec 24 compulsory category;
  • (b) supplying ice cream/edible ice, pan masala, tobacco (Ch 24), fly ash bricks/blocks/aggregates, bricks of fossil meals, building bricks, or earthen/roofing tiles;
  • (c) making intra-State supply in Arunachal Pradesh, Uttarakhand, Meghalaya, Sikkim, Telangana, Puducherry or the 4 special category States;
  • (d) registering voluntarily.

The rest of Section 22 handles succession: existing-law registrants are liable from the appointed day [22(2)]; on transfer or succession of a business (including death of the proprietor) the transferee is liable from the date of transfer [22(3)]; and in an amalgamation/demerger, from the date the RoC issues the certificate of incorporation [22(4)].

Section 23 — not liable to register:

  • (a) persons exclusively supplying non-taxable or wholly exempt goods/services;
  • (b) an agriculturist, for produce out of cultivation of land (individual/HUF only);
  • Government-notified categories under 23(2), A to F: A. exclusive suppliers of outward-RCM u/s 9(3) supplies (Notif 5/2017 CT) — except metal scrap (Ch 72–81) dealers; B. inter-State taxable services up to ₹20L/₹10L (Notif 10/2017 IT); C. inter-State notified handicraft goods up to ₹20L/₹10L with PAN + e-way bill (Notif 3/2018 IT); D. CTPs supplying inter-State notified handicraft goods, same limits (Notif 56/2018 CT); E. services through an ECO up to ₹20L/₹10L (Notif 65/2017 CT); F. intra-State goods through an ECO within the Sec 22(1) threshold, conditions including PAN + one State only (Notif 34/2023 CT);
  • APMC commission agent (Circular 57/31/2018): not liable if the principal (agriculturist) is non-taxable and the invoice is raised by the principal directly; the commission itself is exempt (Notif 12/2017 CT(R)).

Section 24 — compulsory registration, 11 categories (no threshold — overrides Sec 22):

Key points
  • 1. Inter-State taxable supply — exception: services and notified handicraft goods keep threshold shelter.
  • 2. Casual taxable persons — exception: notified handicraft goods (Notif 56/2018).
  • 3. Persons paying tax under RCM (inward) — while exclusive outward-RCM u/s 9(3) suppliers stay exempt, except metal scrap.
  • 4. Non-resident taxable persons.
  • 5. E-commerce trio — (i) ECO collecting TCS, (ii) person paying tax u/s 9(5), (iii) suppliers through an ECO — exception: services via ECO and intra-State goods via ECO keep shelter.
  • 6. TDS deductors (Sec 51).
  • 7. Agents supplying on behalf of others.
  • 8. Input Service Distributors.
  • 9. OIDAR suppliers (outside India → India).
  • 10. Online money gaming suppliers (outside India → India).
  • 11. Other notified persons.

Trap: the Sec 23 exemption is lost if the person also falls under a Sec 24 category (e.g. an RCM liability).

Procedure — Sections 25 to 28

Where and when [25(1)]: apply within 30 days of becoming liable, in every State from which the taxable supply is made; CTP/NRTP must apply at least 5 days before commencing business. The application pipeline:

Key points
  • Rule 8 — REG-01 Part A (PAN + State) → TRN → Part B + documents.
  • Rule 9 — verification: grant in 7 working days if Aadhaar-authenticated and no SCN; 30 days if no Aadhaar or site verification is needed (physical verification report: 5 WD pre-registration, Rule 25); reply to an SCN in 7 WD.
  • Sec 25(11)/(12) — deemed granted if no deficiency notice is issued in time.
  • Rule 10 — REG-06 certificate in 3 days; effective date = date of liability if applied within 30 days, else date of grant.
  • GSTIN — 15 digits: State code + PAN + entity code + checksum.

The supporting provisions:

  • PAN is mandatory [25(6)]; a TDS deductor may use TAN; an NRTP uses other documents — self-attested passport / tax ID (Rule 13).
  • Aadhaar authentication is mandatory [25(6A)–(6D)] — failure makes the registration invalid; existing registrants must authenticate too, within 30 days of allotment (Rule 10B).
  • Bank details (Rule 10A): furnish within 30 days of grant or before filing GSTR-1, whichever is earlier.
  • Voluntary registration [25(3)]: a person not liable may register — then all provisions apply, including tax payment.
  • One registration per State [25(2)]; separate registration per place of business is optional (Rule 11 — separate REG-01 for each; tax invoice needed on inter-branch supply). Each registration is a distinct person [25(4)/(5)].
  • Suo motu registration [25(8), Rule 16]: the proper officer registers a defaulter temporarily; regularise by applying within 90 days, or within 30 days of the Appellate Authority’s order if appealed.
  • UIN [25(9)/(10), Rule 17]: granted to UN bodies/embassies for refunds, within 3 working days. TDS/TCS registration is also granted in 3 working days (Rule 12).
  • Display (Rule 18): registration certificate + GSTIN on the name board at the principal and every additional place of business.
  • Deemed registration [Sec 26]: grant or rejection under SGST = deemed grant or rejection under CGST (mirror).
  • CTP/NRTP [Sec 27]: certificate valid for the period applied or 90 days, whichever is earlier; extendable by a maximum of 90 more days (Rule 15 — apply before expiry with additional deposit); estimated tax must be deposited in advance, credited to the electronic cash ledger.
  • Amendment [Sec 28, Rule 19]: apply within 15 days of the change. Core fields (legal name without PAN change, principal/additional place of business without State change, stakeholders) need PO approval within 15 working days; non-core fields are self-amended instantly; SCN if the amendment is unwarranted (reply in 7 WD). A PAN change or State change is not an amendment — it needs a fresh Sec 25 registration.

Cancellation, suspension and revocation — Sections 29 and 30

Cancellation on application [29(1), Rule 20]: business discontinued or transferred, person no longer liable, or a voluntary registrant opting out — apply within 30 days of the event. A UIN holder cannot apply.

Suo motu cancellation [29(2)]: contravention, non-filing, or fraud — always after an opportunity of hearing. The non-filing triggers:

TaxpayerNon-filing triggerWhere
Composition taxpayerReturn not filed for 3 months beyond due date29(2)(b)
Regular monthly filer6 continuous months of non-filingRule 21(h)
QRMP filer2 tax periods of non-filingRule 21(i)
Voluntary registrantBusiness not commenced within 6 months29(2)(d)

Rule 21 lists 9 contraventions justifying cancellation: no business conducted from the declared place; bogus invoices (invoice without supply); violation of Sec 171; violation of Rule 10A (bank details); Sec 16 ITC violations; GSTR-1 vs GSTR-3B mismatch; violation of Rule 86B; violation of the Rule 23(1) proviso; and the 6-month/2-period non-filing grounds.

Procedure (Rule 22): SCN with 7 days to reply; order within 30 days. Cancellation does not wipe out past dues [29(3)], and SGST cancellation = deemed CGST cancellation [29(4)]. Amount payable [29(5)/(6), Rule 44]: higher of the ITC reversal or the output tax — for capital goods, ITC × remaining life/60 months (deemed 5-year life) versus tax on the transaction value u/s 15; for inputs, pro-rata ITC per invoice/market price versus output tax.

Suspension (Rule 21A): a temporary freeze pending cancellation proceedings — no taxable supply, no returns required. On a voluntary cancellation application, deemed suspension runs from the later of the application date or the date from which cancellation is sought; the PO can also initiate it.

Revocation [Sec 30, Rule 23] — only for suo motu cancellations:

  • Apply within 90 days of the cancellation order; the Commissioner / Additional or Joint Commissioner can extend by up to 180 days more.
  • SCN reply in 7 working days; order within 30 days; SGST revocation = deemed CGST revocation [30(3)].
  • File all pending returns within 30 days of the revocation order — covering the period from the (retrospective or actual) cancellation effective date up to the revocation order date.
  • No revocation possible for registrations cancelled on the registrant’s own application or by legal heirs; UIN holders and GST Practitioners are outside the revocation route.

Key timelines

PeriodEventWhere
30 daysApply for registration from the date liable25(1)
5 days (before)CTP/NRTP apply before commencement25(1)
7 working daysGrant if Aadhaar authenticated, no SCNRule 9
30 daysGrant if no Aadhaar / site verification neededRule 9
7 working daysReply to SCN on applicationRule 9
3 daysREG-06 certificate issued after grantRule 10
30 daysFurnish bank details from grant OR before GSTR-1, earlierRule 10A
30 daysExisting registrant authenticates Aadhaar after allotmentRule 10B
3 working daysTDS/TCS registration grantedRule 12
3 working daysUIN grantedRule 17
90 daysSuo motu registrant applies for regular registration25(8)
30 daysSuo motu — apply after Appellate Authority order25(8)
90 daysCTP/NRTP certificate validity (or period applied, earlier)27(1)
+90 daysExtension of CTP/NRTP validity (maximum)27(1)
15 daysApply for amendment of particulars28 / Rule 19
15 working daysPO acts on core-field amendmentRule 19
7 working daysReply to amendment SCNRule 19
30 daysApply for cancellation (voluntary) from the eventRule 20
7 daysReply to cancellation SCN (suo motu)Rule 22
30 daysPO order on cancellation application / after SCN replyRule 22
3 months beyond due dateComposition taxpayer non-filing → cancellable29(2)(b)
6 months continuousRegular monthly filer non-filing → cancellableRule 21(h)
2 tax periodsQRMP filer non-filing → cancellableRule 21(i)
6 monthsVoluntary registrant not commenced business → cancellable29(2)(d)
90 daysApply for revocation from the cancellation order30(1)
+180 daysExtension of revocation period (Commissioner / Addl–Joint Commr)30(1)
7 working daysReply to revocation SCNRule 23
30 daysPO order on revocation applicationRule 23
30 daysFile pending returns after revocation orderRule 23
15 working daysPhysical verification report post-registrationRule 25
5 working daysPhysical verification report pre-registrationRule 25

Penalty note: this chapter has no penalty provision of its own. Failure to register attracts the general penalty under Sec 122 (Offences chapter), and the Rule 44 ITC payback on cancellation is a payment obligation, not a penalty.

Common mistakes
  • Testing the threshold on “turnover in a State” — the threshold runs on all-India aggregate turnover of the same PAN; State turnover only computes composition tax.
  • Giving ₹40 lakh to every goods supplier — it is for exclusive goods suppliers only, and the four exceptions (Sec 24 categories, notified goods like ice cream/pan masala/tobacco/bricks, the six ₹20L States + 4 special States, voluntary registrants) pull it back.
  • Applying ₹10 lakh to all 11 special category States — only Mizoram, Tripura, Manipur, Nagaland; the other 7 follow the normal ₹40/20 lakh rule.
  • Forgetting that Sec 24 overrides both Sec 22 and Sec 23 — an exempt supplier or agriculturist with an RCM liability must still register.
  • Mixing CTP and NRTP — CTP has a registered business elsewhere in India and a business test; NRTP has no fixed place or residence anywhere in India and no business test; both apply 5 days in advance and neither can opt for composition.
  • Counting inward RCM supplies in aggregate turnover — inward RCM is excluded from the recipient’s turnover; outward RCM supplies are included in the supplier’s.
  • Treating a UIN holder as a registered person — Sec 2(94) specifically excludes UIN holders, and a UIN holder is not a taxable person either.
  • Changing PAN or moving to another State by “amendment” — both require a fresh Sec 25 registration, not an amendment.

Quick revision cards

Threshold ladder by State?

₹10L: Manipur, Mizoram, Nagaland, Tripura · ₹20L: Arunachal, Meghalaya, Sikkim, Uttarakhand, Puducherry, Telangana · elsewhere ₹20L services/mixed, ₹40L exclusive goods.

Sec 24 — the 11 compulsory categories?

Inter-State supply · CTP · RCM payer · NRTP · e-commerce trio (ECO-TCS, 9(5) payer, ECO supplier) · TDS deductor · agent · ISD · OIDAR · online money gaming · other notified. No threshold.

Effective date of registration (Rule 10)?

Applied within 30 days of liability → date of liability; applied late → date of grant.

Grant timelines under Rule 9?

7 working days with Aadhaar authentication; 30 days if no Aadhaar or site verification; REG-06 within 3 days of grant.

CTP/NRTP validity and deposit?

Earlier of period applied or 90 days, extendable max 90 more; apply 5 days before start with advance deposit of estimated tax.

Amendment in one line?

Apply in 15 days; core fields (name, place of business, stakeholders) need PO approval in 15 WD; non-core instant; PAN/State change = fresh registration.

Non-filing → cancellation triggers?

Composition: 3 months beyond due date · monthly filer: 6 continuous months · QRMP: 2 tax periods · voluntary registrant idle: 6 months.

Revocation window?

90 days from the suo motu cancellation order + up to 180 days extension; all pending returns within 30 days of the revocation order.

Amount payable on cancellation (Rule 44)?

Higher of ITC reversal or output tax — capital goods: ITC × remaining life/60 months vs tax on transaction value.

GSTIN structure?

15 digits = State code + PAN + entity code + checksum.

UIN holder's status?

Refund identity for UN bodies/embassies — not a registered person, not a taxable person, cannot apply for cancellation or revocation.

Aggregate turnover — in and out?

In: taxable + exempt + exports + inter-State (all-India, same PAN) and outward RCM. Out: CGST/SGST/IGST/cess and inward RCM.