Who Must Register

The threshold — Section 22

The ₹40 lakh limit for goods is not available to a person making inter-State supplies, a casual taxable person, a person liable under reverse charge, a person supplying specified goods such as ice cream, pan masala and tobacco, or a person registering voluntarily. Some States have not adopted the higher limit. The applicable figure should therefore be confirmed for the specific State and activity rather than assumed.

Aggregate turnover is computed on an all-India PAN basis and includes taxable supplies, exempt supplies, exports and inter-State supplies of persons having the same PAN, but excludes the tax components. A business measuring only its taxable turnover in one state will understate the figure.

Compulsory registration irrespective of turnover — Section 24

• Persons making any inter-State taxable supply — with a limited exemption available for suppliers of services below the threshold
• Casual taxable persons making taxable supplies
• Persons required to pay tax under reverse charge
• Electronic commerce operators required to pay tax under Section 9(5) on specified services
• Non-resident taxable persons
• Persons required to deduct tax at source under Section 51
• Persons who supply goods or services as an agent on behalf of another taxable person
• Input Service Distributors
• Persons supplying through an electronic commerce operator required to collect tax at source — with an exemption available for suppliers of services below the threshold
• Every electronic commerce operator required to collect tax at source under Section 52
• Persons supplying online information and database access or retrieval services from outside India to an unregistered person in India

Persons not liable — Section 23

Persons engaged exclusively in supplying goods or services that are wholly exempt or not liable to tax, and agriculturists to the extent of supply of produce out of the cultivation of land, are not liable to register. The interaction between Sections 22, 23 and 24 has been the subject of amendment, and the position for a business making a mix of exempt and taxable supplies should be assessed on its facts.

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Categories of Registration

Multiple registrations in one State. A person with more than one place of business in a State or Union Territory may obtain a separate registration for each place of business, subject to conditions. This is a choice, and it has consequences for credit flow and compliance workload.

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Documents Required

Identity and constitution

• PAN of the business or applicant — mandatory
• Aadhaar of the authorised signatory and promoters, for authentication
• Photographs of proprietor, partners, directors, karta or trustees
• Constitution documents — partnership deed, certificate of incorporation with memorandum and articles, LLP agreement, or registration certificate of a society or trust. A proprietorship files no separate constitution document
• Identity and address proof of promoters, partners, directors or karta

Principal and additional places of business

• Owned premises — property tax receipt, municipal khata copy, or an electricity bill
• Rented or leased premises — the rent or lease agreement, together with the owner’s ownership proof or electricity bill
• Premises used with consent — a consent letter or no objection certificate from the owner, with the owner’s ownership document
• Photographs of the premises, showing the signage where required
• Where the premises is shared or a co-working space, documentation establishing the applicant’s right to occupy the specific address

Banking and authorisation

• Bank account details — a cancelled cheque, bank statement or the first page of the passbook, in the name of the business. Under Rule 10A these must be furnished within the prescribed period after grant of registration, or before filing the first outward supply return, whichever is earlier
• Authorisation letter or board resolution appointing the authorised signatory
• Digital signature certificate, which is mandatory for companies and limited liability partnerships; other applicants may verify by electronic verification code

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The Process

Step 1 — Part A of Form GST REG-01. PAN, mobile number and email address are submitted and verified by one-time password. A Temporary Reference Number is generated.

Step 2 — Part B. Business details, promoters and partners, authorised signatory, principal and additional places of business, goods and services with HSN and SAC codes, bank details and state-specific information, with the supporting documents uploaded. Part B must be completed within the validity of the TRN.

Step 3 — Acknowledgement. An Application Reference Number is generated in Form GST REG-02.

Step 4 — Verification.

• Where Aadhaar authentication is successfully completed, the application is ordinarily processed within seven working days
• Where Aadhaar authentication is not opted for or fails, or where the officer considers it necessary, the application is subject to physical verification of the place of business, and the processing period extends to thirty days from submission
• Biometric-based Aadhaar authentication has been notified in a growing number of States and Union Territories, requiring the applicant or authorised signatory to attend a designated facilitation centre in person with original documents

Step 5 — Query and reply. Where the officer finds the application deficient, a notice is issued in Form GST REG-03, and the reply must be filed in Form GST REG-04 within the prescribed period, ordinarily seven working days.

Step 6 — Grant or rejection. On approval, the registration certificate is issued in Form GST REG-06 with a fifteen-digit GSTIN. Rejection is communicated in Form GST REG-05, with reasons.

Deemed registration. Where the proper officer does not take action within the prescribed period, the application is treated as approved.

The GSTIN structure: two digits for the State code, ten characters of the PAN, one digit for the number of registrations against that PAN in the State, a default letter, and a checksum character.

Timelines and verification requirements have been amended repeatedly. Confirm the current position before planning around them.

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Amendment, Suspension and Cancellation

Amendment — Section 28

• Core fields — legal name of business, principal or additional place of business, and addition or deletion of partners, directors, karta or managing committee members — require approval by the proper officer, ordinarily within fifteen working days
• Non-core fields — most other particulars, including bank details, authorised signatory contact details and goods and services — are amended automatically on the portal
• A change in PAN cannot be amended; it requires a fresh registration
• A change in the constitution of business resulting in a change of PAN requires fresh registration and cancellation of the old one

Suspension — Rule 21A

Registration may be suspended pending cancellation proceedings, or where the officer finds significant differences or anomalies between the returns furnished and the outward supplies reported by suppliers. A suspended taxpayer cannot make taxable supplies or issue tax invoices.

Cancellation — Section 29

Registration may be cancelled on application where the business has been discontinued, transferred, amalgamated, demerged or otherwise disposed of, where there is a change in constitution requiring a new PAN, or where the person is no longer liable to be registered.

It may be cancelled by the proper officer where:

• The registered person has not filed returns for the prescribed continuous period
• A person who registered voluntarily has not commenced business within six months
• Registration was obtained by fraud, wilful misstatement or suppression of facts
• The registered person does not conduct business from the declared place
• Invoices are issued without supply of goods or services
• Other prescribed contraventions

Cancellation does not extinguish liability. Tax, interest and penalty due for any period before cancellation remain payable, and a final return in Form GSTR-10 must be filed within the prescribed period after cancellation.

Revocation — Section 30

Where registration has been cancelled by the officer on his own motion, the registered person may apply for revocation of cancellation within the prescribed period, which is subject to extension by the specified authorities. Revocation ordinarily requires all pending returns to be filed and dues paid. The applicable period and any extension mechanism should be confirmed on the portal, as this provision has been amended and has also been the subject of periodic amnesty schemes.

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After Registration

Display. The registration certificate must be displayed at a prominent location at the principal place of business and at every additional place of business, and the GSTIN must be displayed on the name board at the entry.

Invoicing. Tax invoices, bills of supply, credit and debit notes in the prescribed form, with the required particulars. E-invoicing through the Invoice Registration Portal applies to businesses above the notified aggregate turnover threshold, and there are time limits within which invoices must be reported for larger taxpayers.

Returns.

Input tax credit. Section 16 conditions must be satisfied — possession of a tax invoice, receipt of the goods or services, tax actually paid to the Government, the return filed, and payment to the supplier within the prescribed period. Credit reflected in the auto-populated statement is the operative constraint in practice. Section 17(5) blocks credit on specified items regardless of business use.

E-way bills for movement of consignments above the notified value.

Records under Section 35, maintained at the principal place of business and retained for the prescribed period.

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Penalties

A business trading unregistered also cannot issue a tax invoice, cannot collect GST, and cannot claim input tax credit for that period — which is frequently a larger commercial loss than the penalty itself.

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Common Mistakes

1. Relying on the turnover threshold while falling within a Section 24 compulsory category
2. Not registering before making the first inter-State supply
3. Selling on an e-commerce marketplace without registration
4. Computing aggregate turnover State-wise rather than on an all-India PAN basis
5. Operating from additional places of business — warehouses, branches, fulfilment centres — that are not declared on the registration
6. Failing to register in a State where a warehouse or service location creates a place of supply
7. Attending an exhibition or trade fair in another State without a casual taxable person registration
8. Address documentation that does not match — rent agreement in one name, electricity bill in another, no consent letter from the owner
9. Premises photographs without signage, leading to rejection on physical verification
10. Bank account details not furnished within the period prescribed by Rule 10A
11. Choosing composition levy while making inter-State outward supplies or supplying through an e-commerce operator, which the scheme does not permit
12. Not obtaining a separate registration for an SEZ unit
13. Core field amendments — change of address or directors — not applied for, leaving the registration inconsistent with reality
14. Returns not filed, leading to suspension and then cancellation
15. Not filing GSTR-10 after cancellation, leaving the liability open
16. Missing the revocation window after a cancellation order, and having to apply afresh

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How Delhi Legal Company Assists

• Liability assessment — whether registration is required at all, whether a Section 24 category applies irrespective of turnover, and in which States, based on your supply chain and place of supply analysis
• Category selection — regular, composition, casual taxable person, non-resident, ISD, TDS or TCS, and separate registrations for SEZ units and multiple places of business
• Application preparation and filing in Form GST REG-01, with document review before submission so that address, constitution and signatory documentation is internally consistent
• Aadhaar and biometric authentication guidance, and preparation for physical verification of premises
• Query handling — replies in Form GST REG-04 within time, and follow-up through to grant
• Amendments — core and non-core field changes, additional places of business, change in constitution
• Suspension and cancellation — replies to show cause notices, applications for revocation, filing of pending returns and GSTR-10
• Post-registration compliance — invoicing and e-invoicing readiness, return calendar, input tax credit review and record-keeping systems
• Notices and litigation — replies to departmental notices, adjudication, appeals and representation

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Frequently Asked Questions (FAQs)

1. Who is required to register under GST?

A. Every supplier whose aggregate turnover in a financial year exceeds the applicable threshold — ordinarily ₹20 lakh, ₹40 lakh for a business supplying only goods subject to conditions, and ₹10 lakh in specified special category States. In addition, Section 24 requires registration irrespective of turnover for a range of categories, and those override the threshold entirely.

2. Who must register regardless of turnover?

A. Persons making inter-State taxable supplies, casual taxable persons, persons liable to pay tax under reverse charge, non-resident taxable persons, agents supplying on behalf of others, input service distributors, persons supplying through an e-commerce operator required to collect tax at source, e-commerce operators themselves, TDS deductors, and overseas suppliers of OIDAR services to unregistered Indian recipients.

3. How is aggregate turnover calculated?

A. On an all-India basis for persons having the same PAN, including taxable supplies, exempt supplies, exports and inter-State supplies, but excluding the tax components. Measuring only taxable turnover in one State understates the figure and is a common reason for a missed registration obligation.

4. Is GST registration required separately in each State?

A. Yes. GST registration is State-wise, not entity-wise. A single legal entity operating in four States requires four registrations, each with its own GSTIN, returns and compliance calendar. Within a State, a person with multiple places of business may also opt for separate registrations for each.

5. Can I register voluntarily below the threshold?

A. Yes, under Section 25(3), and many businesses do so in order to claim input tax credit and to supply to registered customers who require a tax invoice. A voluntary registrant is subject to all the obligations of a registered person, and a voluntary registration may be cancelled if business is not commenced within six months.

6. How long does registration take?

A. Where Aadhaar authentication is successfully completed, ordinarily seven working days. Where authentication is not opted for or fails, or where the officer directs physical verification of the premises, the period extends to about thirty days. Queries raised in Form REG-03 pause the process until the reply is filed.

7. What is biometric Aadhaar authentication?

A. In a growing number of States and Union Territories, applicants flagged by the system must attend a designated facilitation centre in person for biometric verification and document authentication before registration is granted. It should be planned for, because it adds an in-person step to what applicants often expect to be an online process.

8. What address proof is acceptable?

A. For owned premises, a property tax receipt, municipal khata copy or electricity bill. For rented premises, the rent or lease agreement together with the owner’s ownership proof or electricity bill. Where premises are used with permission, a consent letter or no objection certificate together with the owner’s document. The names and address across the documents must be consistent, because mismatches are a leading cause of rejection.

9. Can I register a business at my residential address?

A. Yes, provided the address documentation supports it. Where the premises is owned by a family member, a consent letter with the owner’s ownership proof is required. The officer may still direct physical verification, so the address must be one at which the business can actually be located.

10. Do I need a bank account before applying?

A. Not to submit the application, but bank account details in the name of the business must be furnished under Rule 10A within the prescribed period after grant of registration, or before filing the first outward supply return, whichever is earlier. Failure to do so can result in suspension of the registration.

11. What is a casual taxable person?

A. A person who occasionally undertakes transactions involving supply of goods or services in a State where they have no fixed place of business — typically for exhibitions, trade fairs and seasonal sales. Registration must be applied for at least five days before commencement, an advance deposit of estimated tax is required, and the registration is valid for ninety days, extendable by a further ninety.

12. What is the composition scheme and who can opt for it?

A. A simplified scheme under Section 10 for taxpayers below the prescribed turnover limit, involving a concessional rate on turnover with quarterly payment and an annual return. The trade-offs are significant — no input tax credit, tax cannot be collected from customers, no inter-State outward supplies, and no supply through an e-commerce operator required to collect tax at source.

13. What is an Input Service Distributor and do I need one?

A. An ISD is an office that receives invoices for common input services and distributes the credit to its branches. Following the amendment made by the Finance Act, 2024, the ISD mechanism has been made mandatory for the distribution of common input service credit with effect from the notified date, so groups that previously used cross-charging alone should review their structure.

14. Do SEZ units need separate registration?

A. Yes. A unit or developer in a Special Economic Zone requires a registration distinct from any registration held for a unit in the domestic tariff area in the same State.

15. I sell only on an e-commerce marketplace. Do I need to register?

A. If you supply goods through an e-commerce operator required to collect tax at source, registration is required irrespective of turnover. A limited exemption is available for suppliers of services below the threshold, and specific schemes have been notified for small suppliers of goods, so the position should be confirmed for your particular activity.

16. What is the penalty for not registering?

A. Under Section 122, a penalty of ₹10,000 or the tax evaded, whichever is higher, along with the tax and interest. Equally important commercially, an unregistered business cannot issue a tax invoice, cannot collect GST from customers, and cannot claim input tax credit for that period.

17. Can I change my business address on the registration?

A. Yes, by applying for an amendment. A change in the principal or additional place of business is a core field requiring approval by the proper officer, ordinarily within fifteen working days, and supporting address documents must be furnished. Operating from an undeclared address is a ground for cancellation.

18. What cannot be amended?

A. The PAN. A change in PAN, whether because of a change in the constitution of the business or otherwise, requires a fresh registration and cancellation of the existing one, rather than an amendment.

19. Why was my registration suspended?

A. Suspension under Rule 21A commonly follows non-filing of returns, initiation of cancellation proceedings, or the detection of significant differences between the returns you have filed and the outward supplies reported by your suppliers. A suspended registration cannot be used to make taxable supplies or issue tax invoices, so it should be addressed immediately.

20. On what grounds can registration be cancelled?

A. Under Section 29, on application where the business is discontinued or transferred or the person is no longer liable, and by the officer where returns have not been filed for the prescribed period, where a voluntary registrant has not commenced business within six months, where registration was obtained by fraud or suppression, where the person does not conduct business from the declared place, or where invoices are issued without supply.

21. My registration has been cancelled. What can I do?

A. Apply for revocation within the prescribed period, which is subject to extension by the specified authorities. Revocation ordinarily requires all pending returns to be filed and dues paid. If the revocation window is missed, a fresh registration application becomes necessary — during which the business cannot lawfully collect tax or issue tax invoices.

22. Do I still have obligations after cancellation?

A. Yes. Cancellation does not affect liability for tax, interest or penalty for any period before it, and a final return in Form GSTR-10 must be filed within the prescribed period. Failure to file it is itself a contravention.

23. Do I have to display my GST registration?

A. Yes. The registration certificate must be displayed at a prominent location at the principal place of business and at every additional place of business, and the GSTIN must be displayed on the name board at the entry.

24. What returns will I have to file after registering?

A. A regular taxpayer files GSTR-1 for outward supplies and GSTR-3B for summary and payment, monthly or quarterly under the QRMP scheme, together with the annual return and reconciliation statement above the notified turnover thresholds. Composition taxpayers file CMP-08 and GSTR-4. TDS deductors file GSTR-7 and TCS collectors file GSTR-8.

25. Is e-invoicing mandatory for me?

A. It applies to businesses whose aggregate turnover exceeds the notified threshold, which has been progressively lowered. Larger taxpayers are also subject to time limits within which invoices must be reported to the Invoice Registration Portal. The threshold currently in force should be confirmed, as it has changed several times.

26. What does Delhi Legal Company charge for GST registration?

A. It depends on the number of States, the type of registration, and whether the engagement includes address and constitution documentation, physical verification support and post-registration compliance setup. We quote in writing, and we start with a liability assessment so that you register in the right States, in the right category, at the right time.